"Given that, then there is no gain or loss to be recorded on the SH's personal tax return?"

I don't know if you are asking about capital gain/loss, or operational gain/loss. Sorry.

Everything needs to be valued, then compared in the "swap" the same as if there was buyout, because the Shares traded were used instead of Funds. The distributions are not the buyout, unless perhaps someone got more Funds than they had basis.

It's really a bit too much to break down in the pieces via the internet, and without all the details. You stated an attorney drew up the transfer(s), so someone valued something, to know what to trade out and what that was worth in comparison.