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.
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.
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 addition, if you are entitled to receive Units, you must also provide broker information.
You must designate a broker, bank or other financial institution with which you maintain a securities account to receive your Units on your behalf.