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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.
The Liquidating Trust did not directly own any stock of any foreign corporation.
The Liquidating Trust files income tax returns in those states in which it determines it has a filing obligation.
You must designate a broker, bank or other financial institution with which you maintain a securities account to receive your Units on your behalf.
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.
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.