Tax treatment of liquidating trusts archeomagnetic dating

09, 2017 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today the Trust's trustees have approved a liquidating distribution of

This reference to Black Rock’s website is intended to allow investors public access to information regarding the Fund and does not, and is not intended to, incorporate Black Rock’s website in this release.Black Rock cautions that forward-looking statements are subject to numerous assumptions, risks and uncertainties, which change over time.Forward-looking statements speak only as of the date they are made, and Black Rock assumes no duty to and does not undertake to update forward-looking statements.However, the fact that the corpus of the trust is not supplied by the beneficiaries is not sufficient reason in itself for classifying the arrangement as an ordinary trust rather than as an association or partnership. An investment trust with multiple classes of ownership interests ordinarily will be classified as a business entity under § 301.7701-2; however, an investment trust with multiple classes of ownership interests, in which there is no power under the trust agreement to vary the investment of the certificate holders, will be classified as a trust if the trust is formed to facilitate direct investment in the assets of the trust and the existence of multiple classes of ownership interests is incidental to that purpose.The fact that any organization is technically cast in the trust form, by conveying title to property to trustees for the benefit of persons designated as beneficiaries, will not change the real character of the organization if the organization is more properly classified as a business entity under § 301.7701-2. A corporation purchases a portfolio of residential mortgages and transfers the mortgages to a bank under a trust agreement.

.90 per common beneficial unit in the Trust payable in cash on November 21, 2017 to holders of record on November 14, 2017. After satisfying the debt encumbering this property and all closing costs associated with... 19, 2016 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today the previously announced liquidating distribution of

09, 2017 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today the Trust's trustees have approved a liquidating distribution of $0.90 per common beneficial unit in the Trust payable in cash on November 21, 2017 to holders of record on November 14, 2017. After satisfying the debt encumbering this property and all closing costs associated with... 19, 2016 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today the previously announced liquidating distribution of $1.00 per beneficial interest in the Trust will be paid in cash on August 23, 2016 to holders of record on August 17, 2016. After satisfying all closing costs associated with the sale, the Trust received an aggregate of approximately $46.8 million from the sale.&... 05, 2016 (GLOBE NEWSWIRE) -- Winthrop Realty Trust (the "Company") announced that it has transferred its remaining assets to (and its remaining liabilities were assumed by) Winthrop Realty Liquidating Trust (the "Liquidating Trust") in accordance with the Company's Plan of Liquidation. In addition, Winthrop held the mortgage loan on the property. BOSTON, July 28, 2016 (GLOBE NEWSWIRE) -- Winthrop Realty Trust (NYSE: FUR) (the "Company" or "Winthrop"), which is liquidating and winding down pursuant to a plan of liquidation, announced today its financial and operating results for the second quarter ended June 30, 2016. BOSTON, July 19, 2016 (GLOBE NEWSWIRE) -- Winthrop Realty Trust (NYSE: FUR) ("Winthrop") announced today that its venture which owns 701 Seventh Avenue (a/k/a 20 Times Square) in Times Square area of Manhattan, New York has entered into a lease with The Hershey Company for retail space of approximately 6,940 square feet of space ...

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09, 2017 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today the Trust's trustees have approved a liquidating distribution of $0.90 per common beneficial unit in the Trust payable in cash on November 21, 2017 to holders of record on November 14, 2017. After satisfying the debt encumbering this property and all closing costs associated with... 19, 2016 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today the previously announced liquidating distribution of $1.00 per beneficial interest in the Trust will be paid in cash on August 23, 2016 to holders of record on August 17, 2016. After satisfying all closing costs associated with the sale, the Trust received an aggregate of approximately $46.8 million from the sale.&... 05, 2016 (GLOBE NEWSWIRE) -- Winthrop Realty Trust (the "Company") announced that it has transferred its remaining assets to (and its remaining liabilities were assumed by) Winthrop Realty Liquidating Trust (the "Liquidating Trust") in accordance with the Company's Plan of Liquidation. In addition, Winthrop held the mortgage loan on the property. BOSTON, July 28, 2016 (GLOBE NEWSWIRE) -- Winthrop Realty Trust (NYSE: FUR) (the "Company" or "Winthrop"), which is liquidating and winding down pursuant to a plan of liquidation, announced today its financial and operating results for the second quarter ended June 30, 2016. BOSTON, July 19, 2016 (GLOBE NEWSWIRE) -- Winthrop Realty Trust (NYSE: FUR) ("Winthrop") announced today that its venture which owns 701 Seventh Avenue (a/k/a 20 Times Square) in Times Square area of Manhattan, New York has entered into a lease with The Hershey Company for retail space of approximately 6,940 square feet of space ...

17, 2017 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today the Trust's trustees have approved a liquidating distribution of $0.60 per common beneficial unit in the Trust payable in cash on August 29, 2017 to holders of record on August 22, 2017. BOSTON, June 30, 2017 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today the sale of its Orlando, Florida property to an independent third party for a gross purchase price of approximately $34.8 million. 11, 2016 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today the sale of its One East Erie office property located in Chicago, Illinois. 01, 2016 (GLOBE NEWSWIRE) -- Winthrop Realty Trust (NYSE: FUR) ("Winthrop") announced today the sale of the Mentor Building in Chicago, Illinois which was held by a venture in which Winthrop holds a 49.9% interest.

At the same time, the bank as trustee delivers to the corporation certificates evidencing rights to payments from the pooled mortgages; the corporation sells the certificates to the public.

The trustee holds legal title to the mortgages in the pool for the benefit of the certificate holders but has no power to reinvest proceeds attributable to the mortgages in the pool or to vary investments in the pool in any other manner. Holders of class A certificates are entitled to all payments of mortgage principal, both scheduled and prepaid, until their certificates are retired; holders of class B certificates receive payments of principal only after all class A certificates have been retired.

.00 per beneficial interest in the Trust will be paid in cash on August 23, 2016 to holders of record on August 17, 2016. After satisfying all closing costs associated with the sale, the Trust received an aggregate of approximately .8 million from the sale.&... 05, 2016 (GLOBE NEWSWIRE) -- Winthrop Realty Trust (the "Company") announced that it has transferred its remaining assets to (and its remaining liabilities were assumed by) Winthrop Realty Liquidating Trust (the "Liquidating Trust") in accordance with the Company's Plan of Liquidation. In addition, Winthrop held the mortgage loan on the property. BOSTON, July 28, 2016 (GLOBE NEWSWIRE) -- Winthrop Realty Trust (NYSE: FUR) (the "Company" or "Winthrop"), which is liquidating and winding down pursuant to a plan of liquidation, announced today its financial and operating results for the second quarter ended June 30, 2016. BOSTON, July 19, 2016 (GLOBE NEWSWIRE) -- Winthrop Realty Trust (NYSE: FUR) ("Winthrop") announced today that its venture which owns 701 Seventh Avenue (a/k/a 20 Times Square) in Times Square area of Manhattan, New York has entered into a lease with The Hershey Company for retail space of approximately 6,940 square feet of space ...

17, 2017 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today the Trust's trustees have approved a liquidating distribution of

09, 2017 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today the Trust's trustees have approved a liquidating distribution of

This reference to Black Rock’s website is intended to allow investors public access to information regarding the Fund and does not, and is not intended to, incorporate Black Rock’s website in this release.Black Rock cautions that forward-looking statements are subject to numerous assumptions, risks and uncertainties, which change over time.Forward-looking statements speak only as of the date they are made, and Black Rock assumes no duty to and does not undertake to update forward-looking statements.However, the fact that the corpus of the trust is not supplied by the beneficiaries is not sufficient reason in itself for classifying the arrangement as an ordinary trust rather than as an association or partnership. An investment trust with multiple classes of ownership interests ordinarily will be classified as a business entity under § 301.7701-2; however, an investment trust with multiple classes of ownership interests, in which there is no power under the trust agreement to vary the investment of the certificate holders, will be classified as a trust if the trust is formed to facilitate direct investment in the assets of the trust and the existence of multiple classes of ownership interests is incidental to that purpose.The fact that any organization is technically cast in the trust form, by conveying title to property to trustees for the benefit of persons designated as beneficiaries, will not change the real character of the organization if the organization is more properly classified as a business entity under § 301.7701-2. A corporation purchases a portfolio of residential mortgages and transfers the mortgages to a bank under a trust agreement.

.90 per common beneficial unit in the Trust payable in cash on November 21, 2017 to holders of record on November 14, 2017. After satisfying the debt encumbering this property and all closing costs associated with... 19, 2016 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today the previously announced liquidating distribution of

09, 2017 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today the Trust's trustees have approved a liquidating distribution of $0.90 per common beneficial unit in the Trust payable in cash on November 21, 2017 to holders of record on November 14, 2017. After satisfying the debt encumbering this property and all closing costs associated with... 19, 2016 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today the previously announced liquidating distribution of $1.00 per beneficial interest in the Trust will be paid in cash on August 23, 2016 to holders of record on August 17, 2016. After satisfying all closing costs associated with the sale, the Trust received an aggregate of approximately $46.8 million from the sale.&... 05, 2016 (GLOBE NEWSWIRE) -- Winthrop Realty Trust (the "Company") announced that it has transferred its remaining assets to (and its remaining liabilities were assumed by) Winthrop Realty Liquidating Trust (the "Liquidating Trust") in accordance with the Company's Plan of Liquidation. In addition, Winthrop held the mortgage loan on the property. BOSTON, July 28, 2016 (GLOBE NEWSWIRE) -- Winthrop Realty Trust (NYSE: FUR) (the "Company" or "Winthrop"), which is liquidating and winding down pursuant to a plan of liquidation, announced today its financial and operating results for the second quarter ended June 30, 2016. BOSTON, July 19, 2016 (GLOBE NEWSWIRE) -- Winthrop Realty Trust (NYSE: FUR) ("Winthrop") announced today that its venture which owns 701 Seventh Avenue (a/k/a 20 Times Square) in Times Square area of Manhattan, New York has entered into a lease with The Hershey Company for retail space of approximately 6,940 square feet of space ...

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09, 2017 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today the Trust's trustees have approved a liquidating distribution of $0.90 per common beneficial unit in the Trust payable in cash on November 21, 2017 to holders of record on November 14, 2017. After satisfying the debt encumbering this property and all closing costs associated with... 19, 2016 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today the previously announced liquidating distribution of $1.00 per beneficial interest in the Trust will be paid in cash on August 23, 2016 to holders of record on August 17, 2016. After satisfying all closing costs associated with the sale, the Trust received an aggregate of approximately $46.8 million from the sale.&... 05, 2016 (GLOBE NEWSWIRE) -- Winthrop Realty Trust (the "Company") announced that it has transferred its remaining assets to (and its remaining liabilities were assumed by) Winthrop Realty Liquidating Trust (the "Liquidating Trust") in accordance with the Company's Plan of Liquidation. In addition, Winthrop held the mortgage loan on the property. BOSTON, July 28, 2016 (GLOBE NEWSWIRE) -- Winthrop Realty Trust (NYSE: FUR) (the "Company" or "Winthrop"), which is liquidating and winding down pursuant to a plan of liquidation, announced today its financial and operating results for the second quarter ended June 30, 2016. BOSTON, July 19, 2016 (GLOBE NEWSWIRE) -- Winthrop Realty Trust (NYSE: FUR) ("Winthrop") announced today that its venture which owns 701 Seventh Avenue (a/k/a 20 Times Square) in Times Square area of Manhattan, New York has entered into a lease with The Hershey Company for retail space of approximately 6,940 square feet of space ...

17, 2017 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today the Trust's trustees have approved a liquidating distribution of $0.60 per common beneficial unit in the Trust payable in cash on August 29, 2017 to holders of record on August 22, 2017. BOSTON, June 30, 2017 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today the sale of its Orlando, Florida property to an independent third party for a gross purchase price of approximately $34.8 million. 11, 2016 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today the sale of its One East Erie office property located in Chicago, Illinois. 01, 2016 (GLOBE NEWSWIRE) -- Winthrop Realty Trust (NYSE: FUR) ("Winthrop") announced today the sale of the Mentor Building in Chicago, Illinois which was held by a venture in which Winthrop holds a 49.9% interest.

At the same time, the bank as trustee delivers to the corporation certificates evidencing rights to payments from the pooled mortgages; the corporation sells the certificates to the public.

The trustee holds legal title to the mortgages in the pool for the benefit of the certificate holders but has no power to reinvest proceeds attributable to the mortgages in the pool or to vary investments in the pool in any other manner. Holders of class A certificates are entitled to all payments of mortgage principal, both scheduled and prepaid, until their certificates are retired; holders of class B certificates receive payments of principal only after all class A certificates have been retired.

.00 per beneficial interest in the Trust will be paid in cash on August 23, 2016 to holders of record on August 17, 2016. After satisfying all closing costs associated with the sale, the Trust received an aggregate of approximately .8 million from the sale.&... 05, 2016 (GLOBE NEWSWIRE) -- Winthrop Realty Trust (the "Company") announced that it has transferred its remaining assets to (and its remaining liabilities were assumed by) Winthrop Realty Liquidating Trust (the "Liquidating Trust") in accordance with the Company's Plan of Liquidation. In addition, Winthrop held the mortgage loan on the property. BOSTON, July 28, 2016 (GLOBE NEWSWIRE) -- Winthrop Realty Trust (NYSE: FUR) (the "Company" or "Winthrop"), which is liquidating and winding down pursuant to a plan of liquidation, announced today its financial and operating results for the second quarter ended June 30, 2016. BOSTON, July 19, 2016 (GLOBE NEWSWIRE) -- Winthrop Realty Trust (NYSE: FUR) ("Winthrop") announced today that its venture which owns 701 Seventh Avenue (a/k/a 20 Times Square) in Times Square area of Manhattan, New York has entered into a lease with The Hershey Company for retail space of approximately 6,940 square feet of space ...

17, 2017 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today the Trust's trustees have approved a liquidating distribution of [[

09, 2017 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today the Trust's trustees have approved a liquidating distribution of $0.90 per common beneficial unit in the Trust payable in cash on November 21, 2017 to holders of record on November 14, 2017. After satisfying the debt encumbering this property and all closing costs associated with... 19, 2016 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today the previously announced liquidating distribution of $1.00 per beneficial interest in the Trust will be paid in cash on August 23, 2016 to holders of record on August 17, 2016. After satisfying all closing costs associated with the sale, the Trust received an aggregate of approximately $46.8 million from the sale.&... 05, 2016 (GLOBE NEWSWIRE) -- Winthrop Realty Trust (the "Company") announced that it has transferred its remaining assets to (and its remaining liabilities were assumed by) Winthrop Realty Liquidating Trust (the "Liquidating Trust") in accordance with the Company's Plan of Liquidation. In addition, Winthrop held the mortgage loan on the property. BOSTON, July 28, 2016 (GLOBE NEWSWIRE) -- Winthrop Realty Trust (NYSE: FUR) (the "Company" or "Winthrop"), which is liquidating and winding down pursuant to a plan of liquidation, announced today its financial and operating results for the second quarter ended June 30, 2016. BOSTON, July 19, 2016 (GLOBE NEWSWIRE) -- Winthrop Realty Trust (NYSE: FUR) ("Winthrop") announced today that its venture which owns 701 Seventh Avenue (a/k/a 20 Times Square) in Times Square area of Manhattan, New York has entered into a lease with The Hershey Company for retail space of approximately 6,940 square feet of space ...

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09, 2017 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today the Trust's trustees have approved a liquidating distribution of $0.90 per common beneficial unit in the Trust payable in cash on November 21, 2017 to holders of record on November 14, 2017. After satisfying the debt encumbering this property and all closing costs associated with... 19, 2016 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today the previously announced liquidating distribution of $1.00 per beneficial interest in the Trust will be paid in cash on August 23, 2016 to holders of record on August 17, 2016. After satisfying all closing costs associated with the sale, the Trust received an aggregate of approximately $46.8 million from the sale.&... 05, 2016 (GLOBE NEWSWIRE) -- Winthrop Realty Trust (the "Company") announced that it has transferred its remaining assets to (and its remaining liabilities were assumed by) Winthrop Realty Liquidating Trust (the "Liquidating Trust") in accordance with the Company's Plan of Liquidation. In addition, Winthrop held the mortgage loan on the property. BOSTON, July 28, 2016 (GLOBE NEWSWIRE) -- Winthrop Realty Trust (NYSE: FUR) (the "Company" or "Winthrop"), which is liquidating and winding down pursuant to a plan of liquidation, announced today its financial and operating results for the second quarter ended June 30, 2016. BOSTON, July 19, 2016 (GLOBE NEWSWIRE) -- Winthrop Realty Trust (NYSE: FUR) ("Winthrop") announced today that its venture which owns 701 Seventh Avenue (a/k/a 20 Times Square) in Times Square area of Manhattan, New York has entered into a lease with The Hershey Company for retail space of approximately 6,940 square feet of space ...

17, 2017 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today the Trust's trustees have approved a liquidating distribution of $0.60 per common beneficial unit in the Trust payable in cash on August 29, 2017 to holders of record on August 22, 2017. BOSTON, June 30, 2017 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today the sale of its Orlando, Florida property to an independent third party for a gross purchase price of approximately $34.8 million. 11, 2016 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today the sale of its One East Erie office property located in Chicago, Illinois. 01, 2016 (GLOBE NEWSWIRE) -- Winthrop Realty Trust (NYSE: FUR) ("Winthrop") announced today the sale of the Mentor Building in Chicago, Illinois which was held by a venture in which Winthrop holds a 49.9% interest.

At the same time, the bank as trustee delivers to the corporation certificates evidencing rights to payments from the pooled mortgages; the corporation sells the certificates to the public.

The trustee holds legal title to the mortgages in the pool for the benefit of the certificate holders but has no power to reinvest proceeds attributable to the mortgages in the pool or to vary investments in the pool in any other manner. Holders of class A certificates are entitled to all payments of mortgage principal, both scheduled and prepaid, until their certificates are retired; holders of class B certificates receive payments of principal only after all class A certificates have been retired.

]].60 per common beneficial unit in the Trust payable in cash on August 29, 2017 to holders of record on August 22, 2017. BOSTON, June 30, 2017 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today the sale of its Orlando, Florida property to an independent third party for a gross purchase price of approximately .8 million. 11, 2016 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today the sale of its One East Erie office property located in Chicago, Illinois. 01, 2016 (GLOBE NEWSWIRE) -- Winthrop Realty Trust (NYSE: FUR) ("Winthrop") announced today the sale of the Mentor Building in Chicago, Illinois which was held by a venture in which Winthrop holds a 49.9% interest.

At the same time, the bank as trustee delivers to the corporation certificates evidencing rights to payments from the pooled mortgages; the corporation sells the certificates to the public.

The trustee holds legal title to the mortgages in the pool for the benefit of the certificate holders but has no power to reinvest proceeds attributable to the mortgages in the pool or to vary investments in the pool in any other manner. Holders of class A certificates are entitled to all payments of mortgage principal, both scheduled and prepaid, until their certificates are retired; holders of class B certificates receive payments of principal only after all class A certificates have been retired.

.60 per common beneficial unit in the Trust payable in cash on August 29, 2017 to holders of record on August 22, 2017. BOSTON, June 30, 2017 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today the sale of its Orlando, Florida property to an independent third party for a gross purchase price of approximately .8 million. 11, 2016 (GLOBE NEWSWIRE) -- Winthrop Realty Liquidating Trust (the "Trust") announced today the sale of its One East Erie office property located in Chicago, Illinois. 01, 2016 (GLOBE NEWSWIRE) -- Winthrop Realty Trust (NYSE: FUR) ("Winthrop") announced today the sale of the Mentor Building in Chicago, Illinois which was held by a venture in which Winthrop holds a 49.9% interest.

At the same time, the bank as trustee delivers to the corporation certificates evidencing rights to payments from the pooled mortgages; the corporation sells the certificates to the public.

The trustee holds legal title to the mortgages in the pool for the benefit of the certificate holders but has no power to reinvest proceeds attributable to the mortgages in the pool or to vary investments in the pool in any other manner. Holders of class A certificates are entitled to all payments of mortgage principal, both scheduled and prepaid, until their certificates are retired; holders of class B certificates receive payments of principal only after all class A certificates have been retired.

tax treatment of liquidating trusts-84
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This reference to Black Rock’s website is intended to allow investors public access to information regarding the Fund and does not, and is not intended to, incorporate Black Rock’s website in this release.

Black Rock cautions that forward-looking statements are subject to numerous assumptions, risks and uncertainties, which change over time.

Forward-looking statements speak only as of the date they are made, and Black Rock assumes no duty to and does not undertake to update forward-looking statements.

However, the fact that the corpus of the trust is not supplied by the beneficiaries is not sufficient reason in itself for classifying the arrangement as an ordinary trust rather than as an association or partnership. An investment trust with multiple classes of ownership interests ordinarily will be classified as a business entity under § 301.7701-2; however, an investment trust with multiple classes of ownership interests, in which there is no power under the trust agreement to vary the investment of the certificate holders, will be classified as a trust if the trust is formed to facilitate direct investment in the assets of the trust and the existence of multiple classes of ownership interests is incidental to that purpose.

The fact that any organization is technically cast in the trust form, by conveying title to property to trustees for the benefit of persons designated as beneficiaries, will not change the real character of the organization if the organization is more properly classified as a business entity under § 301.7701-2. A corporation purchases a portfolio of residential mortgages and transfers the mortgages to a bank under a trust agreement.

||

This reference to Black Rock’s website is intended to allow investors public access to information regarding the Fund and does not, and is not intended to, incorporate Black Rock’s website in this release.Black Rock cautions that forward-looking statements are subject to numerous assumptions, risks and uncertainties, which change over time.Forward-looking statements speak only as of the date they are made, and Black Rock assumes no duty to and does not undertake to update forward-looking statements.However, the fact that the corpus of the trust is not supplied by the beneficiaries is not sufficient reason in itself for classifying the arrangement as an ordinary trust rather than as an association or partnership. An investment trust with multiple classes of ownership interests ordinarily will be classified as a business entity under § 301.7701-2; however, an investment trust with multiple classes of ownership interests, in which there is no power under the trust agreement to vary the investment of the certificate holders, will be classified as a trust if the trust is formed to facilitate direct investment in the assets of the trust and the existence of multiple classes of ownership interests is incidental to that purpose.The fact that any organization is technically cast in the trust form, by conveying title to property to trustees for the benefit of persons designated as beneficiaries, will not change the real character of the organization if the organization is more properly classified as a business entity under § 301.7701-2. A corporation purchases a portfolio of residential mortgages and transfers the mortgages to a bank under a trust agreement.

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