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30-Apr-2020 16:54

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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.

The Trust is a liquidating trust for federal and, if applicable, state income tax purposes.

David was formerly the Executive Managing Director of Goldin Associates, a leading US restructuring advisory firm. He was promoted to chief operating officer in 2007. Molinaro was a member of the Bear Stearns’ Management and Compensation Committee from 1998 through 2008. from the Syracuse University College of Law where he is a member of the Board of Advisors and its Executive Committee. The Trust maintains a website at where Unitholders may obtain information concerning the Trust. The Trust continues to pursue strategies to maximize the recoveries of the Mortgage Asset portfolio for the benefit of the Unitholders.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.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.

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.



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