What is a liquidating trust
The Trust is a liquidating trust for federal and, if applicable, state income tax purposes.The Liquidating Trust Agreement provides that the Liquidating Trust was “established for the purpose of liquidating and distributing the Liquidating Trust Assets in accordance with Treasury Regulations Section 301.7701-4(d), with no objective to continue or engage in the conduct of a trade or business, except to the extent reasonably necessary to, and consistent with, its liquidating purpose….” The Trust Agreement further provides that “no part of the Liquidating Trust Assets shall be …CAP RE of Vermont, LLC (“Cap Re” ) is a capt ive insurance company incorporated and licensed under the laws of the State of Vermont.
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.
David Pauker is a turnaround manager and restructuring advisor with more than 25 years of experience advising underperforming companies and their investors. to liquidate and distribute assets of the debtors in the Res Cap bankruptcy case. Ray has extensive experience as a chief restructuring officer and plan administrator in notable bankruptcy cases and situations involving Overseas Shipholding Group Inc., Nortel Networks Inc. The Trust’s mortgage assets include mortgage loans, servicer advances, interest income, real estate owned, trading securities, net of costs to sell the assets.
David was formerly the Executive Managing Director of Goldin Associates, a leading US restructuring advisory firm. He was promoted to chief operating officer in 2007. Molinaro was a member of the Bear Stearns’ Management and Compensation Committee from 1998 through 2008. from the Syracuse University College of Law where he is a member of the Board of Advisors and its Executive Committee. The Trust maintains a website at where Unitholders may obtain information concerning the Trust. The Trust continues to pursue strategies to maximize the recoveries of the Mortgage Asset portfolio for the benefit of the Unitholders.
A basis difference as described above could affect the Beneficiary’s taxable income and loss from holding Trust Units, because the basis difference in Units generally will also result in the Beneficiary having a tax basis in its share of the underlying Trust assets that differs from the basis that the Trust uses in computing its taxable income and loss.
A Beneficiary with a basis difference should consult its tax advisor as to whether and how any adjustments should be made as a result of such differing basis to the per Unit Trust items of taxable income and loss as reported by the Trust for the periods that such Beneficiary holds its Units.