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used or disposed of in furtherance of any trade or business.” Consistent with these provisions, and in light of the nature of the Liquidating Trust’s assets, the Liquidating Trust does not believe that to date it has recognized any income that would constitute trade or business income (or unrelated business taxable income or income that is effectively connected to the conduct of a trade or business in the United States, though such characterizations may depend in part on each Unitholder’s unique tax position) , and it does not anticipate that it will do so in the future.
However, there can be no assurance that this will be the case.
In general, that may depend, in part, on the determination as to which Trust assets or liabilities the basis differential is attributable and how to calculate the recovery of basis that is allocable to multiple assets of the same class, such as the litigation claims.
For example, a Beneficiary whose per Unit adjusted tax basis exceeds that of a Unit acquired from the Trust as of December 17, 2013 may conclude that the excess basis is attributable to the Trust’s litigation claims and that, therefore, its per Unit share of the income recognized from specific litigation recoveries is less than that reported by the Trust.
The Liquidating Trust provides Tax Worksheets for Beneficiaries for each of the states in which the Trust files an income tax return via postings on the Trust’s website at:
Previously, he was a Managing Director and Co-Head of Special Situations Trading at HSBC Securities, where he headed up credit research. Doheny was a portfolio manager at Fintech Advisory Inc., a hedge fund focusing on undervalued securities and turnarounds in the U. He received a BA from Allegheny College and a Juris Doctor from Cornell Law School. The Res Cap Liquidating Trust was established in December 2013 under the Second Amended Joint Chapter 11 Plan of Residential Capital, LLC, et al.In addition, if you are entitled to receive Units, you must also provide broker information.You must designate a broker, bank or other financial institution with which you maintain a securities account to receive your Units on your behalf.Effective as of January 15, 2014, the Liquidating Trust contributed those properties (as well as certain interests in mineral rights that have only nominal value) to Res Cap Securities Holdings Co., a wholly-owned U. It is contemplated that the corporate subsidiary is a United States real property holding corporation within the meaning of section 897 of the U. Over the course of 2019, Res Cap Securities Holdings Co owned 19 properties across 15 states and has added and disposed of properties throughout the period.As of June 30, 2019, Res Cap Securities Holdings Co owned 7 properties in 7 states.