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.
Prior to joining UBS, he was the chief executive officer of Braver Stern Securities from 2010-2011. Bonaventure University in 1980 and completed the Harvard Business School Advanced Management Program in 1992. He was also a member of the Board of MBIA Insurance Corporation and Capital Markets Assurance Corporation. Sonkin was Managing Director and Head of the Insured Portfolio Management Division. Sonkin was formerly senior partner and co-chair of the Financial Restructuring Department at the Wall Street law firm Cadwalader, Wickersham & Taft and a member of its Management Committee. Sonkin was a senior partner at the international law firm, King & Spalding, where he was co-chair of King & Spalding’s Financial Restructuring Group and a member of the firm’s Policy Committee. The reduction in the assets held in bailment between December 17, 2013 and December 31, 2017 is primarily attributable to the initial distribution and the bank accounts of the Debtors being novated to the Liquidating Trust following the plan effective date.
Prior thereto, he spent 22 years at Bear Stearns, where he was executive vice president, chief operating officer and chief financial officer of The Bear Stearns Companies Inc. Additional assets were transferred to the Trust as circumstances warranted.
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.
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.
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 is the founder of North Country Capital, an investment and advisory firm where he currently serves as President. Doheny served as a Managing Director and helped lead the Distressed Products Group of Deutsche Bank Securities Inc. Prior to Deutsche Bank, he was a bankruptcy attorney in the corporate reorganization groups of Orrick and Kelley Drye. Doheny currently serves on the boards of YRC Worldwide Inc, Affinity Gaming, Arcapita Inc (RA Holdings) and Eastman Kodak Inc. After his time at Price Waterhouse, he served as a Senior Managing Director at FTI Consulting. Weber has served on the Contra Costa Civil Grand Jury, performed occasional independent consulting projects and assumed board/trustee positions. Weber currently serves on Board of Directors of winery Truett Hurst, Inc., and chairs the audit committee.
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.
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