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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.
Cap Re provided reinsurance on mortgage loans originated by GMAC Mortgage LLC and its affiliates and correspondent lenders through entering into reinsurance agreements with various primary mortgage insurers in which the company assumed the risk of loss in excess of various loss percentages.
Effective December 31, 2008, Cap Re ceased reinsuring new risk, placing the existing reinsurance agreements into run-off in accordance with their terms. As of December 17, 2013, the Effective Date of the Plan, the Liquidating Trust beneficially owned approximately 80 properties located in 34 states. In addition, any real property acquired subsequent to that date in connection with foreclosure proceedings has been and will be conveyed directly to Res Cap Securities Holdings Co., rather than to the Liquidating Trust. Between December 17, 2013 and January 15, 2014, the Trust sold four properties, on which no gain or loss was recognized for income tax purposes.
He was CRO of Refco, a diversified financial services company that was one of the largest-ever US bankruptcies, and has acted as CRO, CEO, turnaround manager or financial advisor for companies in diverse industries, including apparel and textile, energy and natural resources, financial services, food and consumer products, information technology, manufacturing, media and telecommunications, professional services, real estate, retail and wholesale distribution. David is a director of Terra Form Power and reorganized Lehman Brothers. is a Group Managing Director and heads the UBS Non-Core and Legacy division. He was promoted to chief financial officer in 1996 and held that title through 2008. Molinaro has also served as a director of the Securities Industry and Financial Markets Association (SIFMA). Sonkin has lectured and served on panels covering topics such as distressed debt trading, utility restructurings and life insurance company reorganizations. Sonkin is a cum laude graduate of the Temple University College of Liberal Arts where he earned a bachelor’s degree in political science and currently serves as a member of the Board of Visitors. Res Cap Liquidating Trust’s mission is to maximize returns to Unitholders by vigorously pursuing and resolving the mortgage correspondent litigation and monetizing the Trust’s remaining assets in a timely and efficient manner. Section 2.5(b) of the Liquidating Trust Agreement provides that if assets cannot be transferred to the Liquidating Trust by a Debtor entity, or it is impracticable or inadvisable to do so, the Debtor entity will continue to retain those assets until it is notified that the Liquidating Trust may receive the assets.
A Fellow of the American College of Bankruptcy, David has frequently been ranked among leading U. He is a graduate of Cornell University and the Columbia University School of Law. He joined UBS as the chief operating officer of the Investment Bank in March 2012. Molinaro was appointed to the executive committee in 2001 and served as executive vice president of The Bear Stearns Companies Inc. He received a bachelor’s degree in business administration from St. Prior to his role as an advisor, he served as Executive Vice President and Chief Portfolio Officer for the company. Sonkin was responsible for the oversight of MBIA’s 8 billion global portfolio of insured municipal, corporate and structured finance credits, including, all workout, restructuring and litigation related remediation activities. and international workouts and restructurings, corporate reorganization and insolvency matters, and has served as a court appointed examiner. Sonkin has played a significant role in complex structured finance, corporate, infrastructure, utility, healthcare and insurance company reorganizations and served as chief counsel in the rehabilitations of Mutual Benefit Life and Confederation Life Insurance (U. Assets that are held by the Debtor entities under these circumstances are referred to as assets held in bailment.
to liquidate and distribute assets of the debtors in the Res Cap bankruptcy case.
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.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.A Beneficiary that did not acquire its Units from the Trust in the initial distribution as of December 17, 2013 may have an adjusted tax basis per Unit (and therefore an adjusted tax basis in the underlying Trust assets attributable to such Units) that differs from the adjusted basis of a Unit acquired from the Trust as of December 17, 2013.The basis difference per Unit, in general, should equal the difference Between (i) such Beneficiary’s tax basis in each of its Units at the time it acquired such Units and (ii) .02 (the December 17, 2013, tax basis per Unit), increased by the per Unit Trust items of taxable income and gains through the date that the Beneficiary acquired its Units and reduced by the per Unit Trust items of taxable deduction and loss and distributions made through the date that the Beneficiary acquired its Units, in each case as reported by the Trust and available on its website under the heading “financial and tax information.” Because the Trust, in general, does not know the price and date at which such a Beneficiary acquired its Units, it cannot provide this basis information for each Beneficiary.