Liquidating trust tax

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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 Worksheets reflect the income and deductions that the Trust determines should be allocated to each state in which it files an income tax return. Each Unitholder should seek advice from its own tax advisor as to which state income tax returns, if any, it is required to file as a result of owning Units or otherwise and its share of Trust income and deductions, if any, that must be reported on any such state income tax return.

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.

CAP RE of Vermont, LLC (“Cap Re” ) is a capt ive insurance company incorporated and licensed under the laws of the State of Vermont.

Cap Re, which is taxed as a C corporation, was owned by GMAC Mortgage, LLC and is now owned by the Liquidating Trust.

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