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Milk Duds

03/31/25 2:49 PM

#740485 RE: MadBadger #740483

But this quote seems to say the Up-C structure will collapse after the deal is done.

"In addition, Mr. Cooper’s obligations to consummate the Mergers are subject to the receipt by Mr. Cooper of an opinion of counsel to the effect that the Mergers, taken together, will qualify as a “reorganization” within the meaning of Section 368(a) of the Internal Revenue Code of 1986, as amended; and the completion of the collapse of the Company’s “Up-C” structure."
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PickStocks

03/31/25 5:46 PM

#740510 RE: MadBadger #740483

In an Up-C structure, the operating company is owned by a partnership (often a limited partnership), which allows the owners to maintain certain tax benefits and flexibility in ownership. The public company (often a corporation) holds a minority interest in the partnership. This structure can be advantageous for tax purposes, allowing for the deferral of taxes on gains until the partnership interests are sold.  Coop owns 25%....