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REMIC and Related Tax Issues

REMICs are tax events that pertain to the pooling of mortgage loans and the issuance of both residential and commercial mortgage-backed securities. Importantly, REMICs are critical to the basic structure of a Commercial Mortgage-Backed Security. For the past several years, CRE Finance Council along with its industry coalition partners have been seeking modernization of the REMIC rules to keep pace with current transactional needs and reflect current market realities. Below are the REMIC-related issues and items of which the Council is focused.  

 

Featured Documents

> Cadwalader Summary Memo
Details of the Dec. 6 Deadline for REMIC Provisions

IRS Revenue Procedure 2010-30 & Council's Analysis 

>  Council Urges IRS Action on Technical Corrections to REMIC Regulations

> Council, Coalition Letter Warns Against Carried Interest

> CMSAs REMIC White Paper

> Financial Regulators Adopt Guidance on Prudent CRE Loan Workouts 

> Policy Statement on Prudent CRE Loan Workouts

> CMSA-MBA Issue Paper to Address Questions Related to Changes in REMIC Rules

 

  Comment Letters & Testimony     Research / Background Documents

 

July 9, 2011
CREFC, Coalition Warn House About Carried Interest Changes 

July 9, 2011
CREFC, Coalition Warn Senate About Carried Interest Changes 

asterisk_orange June 25, 2010
Council Urges IRS Action on Technical Corrections to REMIC Regulations

asterisk_orange May 19, 2010 
Council, Coalition Letter Warns Against Carried Interest

November 4, 2009
CMSA Urges IRS to Reconsider Application of Recently Issued REMIC Regulations to Collateral Releases

September 30, 2009
ASF Submits Request to IRS on Recently Issued REMIC Regulations

asterisk_orange July 21, 2009
CMSAs REMIC White Paper

March 11, 2008
REMIC Industry Coalition Submits Statement for April 4 Hearing on Proposed REMIC Rules

February 7, 2008
REMIC Industry Coalition Submits Comment Letter on Proposed REMIC Rules 

April 30, 2007
REMIC Industry Coalition Submits Letter on IRS Notice 2007-17 "Modifications of Commercial Mortgage Loans Held by a REMIC"

March 10, 2005
REMIC Industry letter to U.S. Senate

March 4, 2005
REMIC Industry Letter to U.S. House

January 27, 2005
REMIC Industry Coalition List of Permitted Modifications

October 1, 2004
REMIC Industry Coalition Letter to FSC/ETI Conferees

May 19, 2004
REMIC Industry Letter on S. 2422

May 5, 2004
REMIC Industry Letter on HR 4113 

 

 

 

 

 

 

 

 

 

             

asterisk_orange November 16, 2010
Cadwalader Summary Memo
Details of the Dec. 6 Deadline for REMIC Provisions

August 18, 2010
asterisk_orange Analysis of IRS Procedure for REMIC Qualified Mortgages in Connection With Lien Releases 

asterisk_orange August 17, 2010 
IRS Revenue Procedure 2010-30 

asterisk_orange October 30, 2009 
Financial Regulators Adopt Guidance on Prudent CRE Loan Workouts 
Policy Statement on Prudent CRE Loan Workouts

asterisk_orange October 22, 2009
CMSA-MBA Issue Paper to Address Questions Related to Changes in REMIC Rules

September 15, 2009 
CMSA Summary of IRS Guidance on Modifications to Commercial Mortgage Loans 

IRS Issues Final Regulations to Expand Permissible Modifications for Commercial Mortgage Loans held by REMICs 

IRS Issues Revenue Procedure to Describe Conditions for Modifying Commercial Loans with No Tax Consequences 

IRS Issues Notice on Whether Guidance is Necessary for Modifications of  Commercial Mortgage Loans held by Investment Trusts

December 29, 2008 
American Special Servicers Association REMIC Proposal

November 2007
REMIC Reform Position Paper 

November 12, 2007
Memo on Proposed REMIC Rules

November 8, 2007
IRS Proposes Rules on Modifications to REMICs

February 28, 2007
IRS Issues Notice 2007-17, Modifications of Commercial Mortgage Loans Held by a REMIC

March 9, 2005
REMIC Senate Bill 580 Introduced

March 1, 2005
H.R. 1010 - REMIC Modificiation Legislation Introduced in U.S. House 

October 1, 2004
H.R. 4113 - REMIC Modification Legislation
S. 2422 - REMIC Modification Legislation