Mr Cooper Group Inc fka COOP

[ron_66271]

From the WMI Liquidation Trust Q&A.

Answer #6;

“Treasury Regulation 1.468B-9(c)(6) provides that upon the termination of a Disputed Ownership Fund, the claimants to the fund’s net assets succeed to the funds unused net operating loss carryforwards.
This regulation also provides that “if the fund's net assets are distributable to more than one claimant, the unused net operating loss carryover. . . must be allocated among the claimants in proportion to the value of the assets distributable to each claimant from the fund.”
Pursuant to the Plan, the DCR was created and elected to be treated as a “Disputed Ownership Fund” pursuant to Treasury Regulation 1.468B-9(c)(2). On the basis of the foregoing, a beneficiary’s share of the unused net operating loss of the DCR is set forth in the Beneficiary Tax Reporting Letter distributed by the Trust for the year ended December 31, 2020. This amount was calculated by allocating the unused net operating loss of the DCR among the final claimants based on each claimant’s portion of the final cash distribution that was initiated in January 2020.”


You might want to copy this for your account.



Ron