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Income Tax Provision
9 Months Ended
Dec. 31, 2012
Income Tax Provision [Abstract]  
Income Tax Provision

8. Income Tax Provision

The income tax provision for the three months ended December 31, 2012 was determined by computing the deferred tax provision using the enacted statutory rate of 39.6% that goes into effect for the GUC Trust’s fiscal year beginning on April 1, 2013. For prior interim periods, the GUC Trust’s statutory tax rate of 35% was applied. There was no current tax provision during any periods. An annual effective tax rate is not determinable because the GUC Trust’s only significant source of income is gains on distributions or sales of New GM Securities, which are not determinable until realized. The components of the income tax provision in the statements of changes in net assets in liquidation for the three and nine months ended December 31, 2012 and 2011 are as follows:

 

                                 
    Three Months Ended December 31,     Nine Months Ended December 31,  
(in thousands)   2012     2011     2012     2011  

Current

  $ —       $ —       $ —       $ —    

Deferred

    172,039       —         83,774       —    
   

 

 

   

 

 

   

 

 

   

 

 

 

Total

  $ 172,039     $ —       $ 83,774     $ —    
   

 

 

   

 

 

   

 

 

   

 

 

 

Deferred taxes in the accompanying condensed statement of net assets in liquidation at December 31, 2012 are comprised of the following components:

 

         
(in thousands)      

Deferred tax assets:

       

Reserves for expected costs of liquidation

  $ 25,004  

Net operating losses

    19,263  
   

 

 

 

Gross deferred tax assets

    44,267  

Deferred tax liabilities:

       

Fair value in excess of tax basis of holdings of New GM Securities

    (236,624
   

 

 

 

Gross deferred tax liabilities

    (236,624
   

 

 

 

Net deferred tax liability

  $ (192,357
   

 

 

 

Valuation allowances against deferred tax assets aggregating $9.2 million and $27.5 million were provided during the quarter and nine months ended December 31, 2011, respectively, due to uncertainty as to whether the deferred tax assets were realizable. Realization of the deferred tax assets is solely dependent upon the generation of taxable gains upon the distribution or sale of New GM Securities in the future, which is not determinable prior to occurrence.