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."