Rcc liquidating corp 2016 quiana grant dating
476) includes a detailed discussion of the tax consequences of the Plan and the CDC Liquidation Trust in Article IX entitled “Tax Consequences of the Plan, and Disclaimer”, see Disclosure Statement, pp. The tax discussion below in Questions 2 through 5 is taken in substantial part from Article IX of the Disclosure Statement.KCC does not endorse or warrant and is not responsible for any third-party content that may be accessed from this website.Yes, the first distribution to Beneficial Interest holders was made from the CDC Liquidation Trust on or about December 24, 2012.The CDC Liquidation Trust has prepared a summary (the “Summary”) of the information that has been provided by the CDC Liquidation Trust and the Disputed Ownership Fund (“DOF”) to Beneficial Interest holders with respect to tax matters related to the CDC Liquidation Trust and the DOF since their establishment. With the termination of the CDC Liquidation Trust on or about December 19, 2017, a final Summary has been prepared entitled “2017 Final Summary of Information on Tax Matters from the CDC Liquidation Trust and the CDC Corporation Chapter 11 Disputed Ownership Fund” and can be viewed by following this link. In general, a liquidating trust is treated for federal income tax purposes as a “grantor trust.” Under U. federal income tax laws, a grantor trust is disregarded, and the grantors are treated as if they directly own undivided interests in all of the trust’s assets. The applicable Beneficial Interest holders (former shareholders of the Debtor) will be deemed to be the grantors and owners of the CDC Liquidation Trust and its respective Trust Assets. Each Beneficial Interest holder that is a beneficiary of the CDC Liquidation Trust will generally recognize gain or loss in its taxable year that includes the Effective Date in an amount equal to the difference between the amount realized in respect of its Equity Interest and its adjusted tax basis in the Equity Interest.The CDC Liquidation Trust is intended to qualify as a “liquidating trust” as described in Treasury Regulations Section 301.7701-4(d) and Revenue Procedure 94-45, 1994-2 C. The amount realized should generally equal the fair market value of the Trust Assets deemed received for U. federal income tax purposes under the Plan in respect of each Beneficial Interest holder’s Equity Interest.