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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.
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 …
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.
The Liquidating Trust owns all of the stock of two US corporations – RFC Foreign Equity Holding Co. – that owned the stock of several foreign corporations.
The foreign corporations have all been liquidated as of December 31, 2017.
You may email the Trust at [email protected] request a form on which to provide your securities account information or access such form on the Trust’s website here.
A link to the Securities Account Information Form is provided under the section titled “Forms.” The completed forms should be returned promptly to the following email or address: Res Cap Liquidating [email protected] Cap or Res Cap Liquidating Trust P. Box 385220 Bloomington, Minnesota 55438 How could the basis of a Beneficiary’s Units that were not acquired from the Trust in the initial distribution as of December 17, 2013, differ from the basis in Units that a Beneficiary acquired from the Trust in the initial distribution as of December 17, 2013?
The most current financial information can be found in the Consolidated Financial Statements section of this website. Ray III was appointed Liquidating Trust Manager (“LTM”) on November 18, 2016. Ray served as Chief Counsel to the Trust from September 2015. Ray is Senior Managing Director of Greylock Partners, LLC. Ray has served in various capacities with respect to Chapter 11 bankruptcy estates. Ray served as Chief Restructuring Officer of Overseas Shipping Group and from 2014 to 2015, Chairman of the Board of Overseas Shipping Group. Ray has served as the principal officer of Nortel Networks, Inc. Ray served as the Chairman of the Restructuring Committee of the Board of GT Technologies. Ray was Chairman of the post confirmation Board of Enron Corporation and, from 2005 to 2009, President of post confirmation Enron Corporation.
Matt Doheny has over twenty years of experience in the distressed investing, turnaround and restructuring industry. Weber has over 35 years of experience in litigation support and expert witness work, restructuring consulting (both debtor and creditor) and auditing. Weber began his career at Price Waterhouse and served in a variety of positions and practices (including a 2-year foreign tour), leaving as a partner after 22 years.
The Liquidating Trust did not directly own any stock of any foreign corporation.Tags: Adult Dating, affair dating, sex dating