Bankruptcy and Insolvency Taxation, 4th Edition

APPENDIX G

In re Fremont General Corporation: Tax Consequences of Plan

Christopher E. Prince (State Bar No 183553) [e-mail] LESNICK PRINCE LLP 185 Pier Avenue, Suite 103 Santa Monica, CA 90405 Telephone: [phone] Facsimile: [phone]

Carole Neville (Pro Hac Vice Pending) [e-mail] SONNENSCHEIN NATH & ROSENTHAL LLP 1221 Avenue of the Americas New York, New York 10020 Telephone: [phone] Facsimile: [phone] Attorneys for New World Acquisition, LLC

UNITED STATES BANKRUPTCY COURT CENTRAL DISTRICT OF CALIFORNIA SANTA ANA DIVISION

In re	Case No. 8:08-bk-13421-ES
FREMONT GENERAL CORPORATION, a	CHAPTER 11 CASE
Nevada corporation,      Debtor.	NEW WORLD ACQUISITION, LLC’S AMENDED DISCLOSURE STATEMENT WITH RESPECT TO AMENDED CHAPTER 11 PLAN OF REORGANIZATION FOR FREMONT GENERAL CORPORATION (DATED JANUARY 19, 2010)
Taxpayer ID No. 95-2815260

F. TAX CONSEQUENCES OF PLAN

1. Certain Federal Income Tax

Consequences of the Plan

TO ENSURE COMPLIANCE WITH U.S. TREASURY DEPARTMENT CIRCULAR 230, HOLDERS OF CLAIMS AND EQUITY INTERESTS ARE HEREBY NOTIFIED THAT: (A) ANY DISCUSSION OF U.S. FEDERAL TAX ISSUES CONTAINED OR REFERRED TO IN THIS DISCLOSURE STATEMENT IS NOT INTENDED OR WRITTEN TO BE RELIED UPON, AND CANNOT BE RELIED UPON, BY SUCH HOLDERS FOR THE PURPOSE OF AVOIDING PENALTIES THAT MAY BE IMPOSED ON THEM UNDER THE INTERNAL REVENUE CODE OF 1986, AS AMENDED (“TAX CODE”); (B) SUCH DISCUSSION IS WRITTEN IN CONNECTION WITH THE PROMOTION ...