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newflow

05/10/24 5:49 PM

#727626 RE: newflow #727622

LIQUIDATING TRUST INTERESTS THAT MAY GENERATE CASH RECOVERY IN THE EVEN ALL CLAIMS 100% SATISFIED?.

AND GRANTOR TRUST TREATMENT OF TRUST BENEFICIARIES ARE AS OWNERS DIRECTLY RECEIVING DISTRIBUTIONS FROM DEBTORS.
SUCH BENEFICIARY IS ALREADY REGARDED FOR FEDERAL INCOME TAX PURPOSES AS OWNING THE UNDERLYING ASSETS(AND WAS TAXED AT THE TIME THE WAS EARNED OR RECEIVED BY SUCH TRUST)
https://s1.q4cdn.com/275823140/files/doc_downloads/irw/IRS_forms_8937/Mr.-Cooper-Group-WMI-Liquidating-Trust-Disputed-Equity-Escrow-distributions.pdf

Subject to certain limited exceptions, the Liquidating Trust Interests are not transferable or assignable.
LTIs are not transferable or assignable except by will, intestate succession or operation of law. Accordingly, there is no liquid trading market in the LTIs. Under certain circumstances, transfers of LTIs have been permitted upon the winding up or dissolution of vehicles that previously held LTIs on behalf of such vehicles or the beneficiaries thereof. There can be no assurance that the Trust will consent to any such transfers in the future.
Page 8
https://www.sec.gov/Archives/edgar/data/1545078/000119312519092649/d658548d10k.htm

FOR THE ABOVE REASONS WMILT WANTED W-9 FROM RELEASING EQUITY HOLDERS.THE ASSETS MUST HAVE BEEN GENERATING CASH FOR A WHILE.