The Res Cap Liquidating Trust was established in December 2013 under the Second Amended Joint Chapter 11 Plan of Residential Capital, LLC, et al.to liquidate and distribute assets of the debtors in the Res Cap bankruptcy case.Matt Doheny has over twenty years of experience in the distressed investing, turnaround and restructuring industry. Weber has over 35 years of experience in litigation support and expert witness work, restructuring consulting (both debtor and creditor) and auditing. Weber began his career at Price Waterhouse and served in a variety of positions and practices (including a 2-year foreign tour), leaving as a partner after 22 years.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.
Under Section 332(d), a liquidating distribution to a foreign corporation of an “applicable holding company” is treated as a dividend (rather than non-taxable income) that generally will be subject to a 30 percent U. An exception exists, however, if the foreign corporation is a CFC. Therefore, it may be possible to convert taxable dividend income into a non-taxable distribution by interposing a U. partnership in between the foreign corporation and its shareholders to cause such foreign corporation to be characterized as a CFC. This may be because the partnership anti-abuse rules themselves contain an example that approves the interposition of a U. partnership in between the shareholders and a foreign corporation for the sole purpose of converting the foreign corporation into a CFC, which would allow the shareholders to take advantage of more favorable foreign tax credit provisions. Other possible avenues of attack include the use of judicial doctrines, such as substance over form, sham transaction and economic substance.Sole proprietors must use the forms that are numbered in the 100 series.If you need help finding a bankruptcy lawyer, the resources below may help.All bankruptcy cases are handled in federal courts under rules outlined in the U. Individuals can file bankruptcy without a lawyer, which is called filing pro se. Use the forms that are numbered in the 100 series to file bankruptcy for individuals or married couples.Use the forms that are numbered in the 200 series if you are preparing a bankruptcy on behalf of a nonindividual, such as a corporation, partnership, or limited liability company (LLC).Bankruptcy helps people who can no longer pay their debts get a fresh start by liquidating assets to pay their debts or by creating a repayment plan.