Accordingly, the
Shareholder generally will recognize gain or loss
on the sale in an amount equal to the difference between (1) the amount realized pursuant to the sale of the Shares, and (2) the
Shareholder's tax
basis for the portion of its
pro rata share of the Bitcoins held by the Trust at the time of sale that is attributable to the Shares sold, as determined in the manner described in the preceding paragraph.
Pursuant to the Plan, the Company is also authorized to dispose of its remaining non-cash assets,
on such terms and at such prices as the Company's board of directors, without further
shareholder approval, may determine to be in the best interests of the Company and its
shareholders, to pay or make reasonable provision to pay all claims against and obligations of the Company, to make such provisions as will be reasonably likely to be sufficient to provide compensation for any claim against the Company which is the subject of a pending action, suit or proceeding to which the Company is a party, to distribute
on a
pro rata basis to the
shareholders of the Company the remaining assets of the Company, and, subject to statutory limitations, to take all other actions necessary to wind up and liquidate the Company's business and affairs.