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Re: newflow post# 727483

Wednesday, 05/08/2024 6:27:51 PM

Wednesday, May 08, 2024 6:27:51 PM

Post# of 728650
DCR - 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.
Page 5
https://www.sec.gov/Archives/edgar/data/1545078/000119312519092649/d658548d10k.htm

"Pursuant to the plan,the liquidating trust assets are treated, for U.S. Federal income tax purposes, as having been transferred directly to the holders of claims or equity interests in satisfaction of their claims or cancellation of their equity interests"
Page 4
https://s1.q4cdn.com/275823140/files/doc_downloads/irw/IRS_forms_8937/Mr.-Cooper-Group-WMI-Liquidating-Trust-Disputed-Equity-Escrow-distributions.pdf

The claims attributable to the funds and LTIs in the DCR are not a liability of the Trust
Assets of the DCR will be made available to the LTI holders in accordance with the Plan as and when disputed claims become disallowed. The claims attributable to the funds and LTIs in the DCR are not a liability of the Trust; therefore, no estimate has been made as to the amount of claims which will ultimately be allowed and the distributions which will go to disputed claimants as opposed to current LTI holders. Rather, the financial statements report the net assets being held specifically on behalf of the disputed claimants and the net asset value available to all LTI holders.
https://www.sec.gov/Archives/edgar/data/1545078/000119312519092649/d658548d10k.htm

So whose liability is equity claims/LTIs in DCR?.
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