15. Accordingly, in August 2016, the Plan Administrator caused LBHI to acquire from LCPI 100% of LCPI’s equity interests in LPTSI for a nominal amount. At that
time, the equity of LPTSI had no value since LPTSI was insolvent. Thereafter, the Plan Administrator caused LBHI to contribute approximately $3.65 million in cash to LPTSI as a capital contribution, which LPTSI used to satisfy in full LPTSI’s debt obligations to its former parent, LCPI. The Plan Administrator also caused LBHI to forgive approximately $93 million of LPTSI’s debt to it and contribute various assets to LPTSI. The result of these actions was to render LPTSI solvent and create value in LBHI’s equity in LPTSI.
16. Similarly, in September 2016, the Plan Administrator caused LBHI to contribute an approximately $8 billion subordinated receivable from LUK as a capital contribution to LUK. Thereafter, the Plan Administrator caused LBHI to contribute various assets to LUK. The effect of these actions was to render LUK solvent and create value in LBHI’s common equity interests in LUK.