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Re: newflow post# 693044

Tuesday, 08/02/2022 9:15:11 PM

Tuesday, August 02, 2022 9:15:11 PM

Post# of 728978
DCR - "Disputed Ownership Fund" "Separate Entity"
Pursuant to the Plan and the Trust Agreement, the Liquidating Trustee (A) treats the DCR as a “disputed ownership fund” governed by Treasury Regulation section 1.468B-9, and (B) to the extent permitted by applicable law, reports consistently with the foregoing for state and local income tax purposes. Accordingly, the DCR is a separate taxable entity for U.S. federal income tax purposes, and all distributions from such reserve are taxable to such reserve as if sold at fair market value. Any distributions from the DCR will be treated for U.S. federal income tax purposes as if received directly by the recipient from the Debtors on the original claim or equity interest of such recipient.
https://www.sec.gov/Archives/edgar/data/1545078/000119312519092649/d658548d10k.htm

COOP EIN 91-1653725
WMILT EIN 45-6794330
DCR EIN 45-4709825

26 CFR § 1.468B-9 - Disputed ownership funds.
Instead, each LTI holder is treated for U.S. federal income tax purposes as a direct owner of an indivisible portion of the underlying assets of the Trust (other than those held on account of disputed claims in the DCR) reflective of its relative economic interest in the Trust.

Did any former equity receive any distributions from DCR on the "Original Equity Interests" YET?

Now see who issued the same for cancelled equity
https://s1.q4cdn.com/275823140/files/doc_downloads/irw/IRS_forms_8937/Mr.-Cooper-Group-WMI-Liquidating-Trust-Disputed-Equity-Escrow-distributions.pdf
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