Certain Modifications of Securitized Loans Won't Jeopardize Tax Status Of REMICs, Investment Trusts

摘要

"Fast track" modifications of securitized subprime mortgages that comply with revised American Securitization Forum (ASF) guidelines won't jeopardize the tax status of real estate mortgage investment conduits (REMICs) or investment trusts, according to the Internal Revenue Service. (Rev. Proc. 2008-47, released July 8, 2008, and scheduled for publication in the August 4 Internal Revenue Bulletin) In addition, the modifications won't be treated as dispositions of qualified mortgages that could create a liability for a tax on prohibited transactions.