We use cookies to customise content for your subscription and for analytics.
If you continue to browse Lexology, we will assume that you are happy to receive all our cookies. For further information please read our Cookie Policy.
Lexology logo






  Request new password

Search results

Order by most recent / most popular / relevance

Results: 1-4 of 4

IRS will not treat public-private investment funds as taxable mortgage pools, allowing the funds to issue tranched debt without incurring a corporate income tax

  • Sidley Austin LLP
  • -
  • USA
  • -
  • August 28 2009

Rev. Proc. 2009-38 announces that the Internal Revenue Service (“IRS”) will not apply the taxable mortgage pool (“TMP”) rules to Public-Private Investment Funds (“Funds”

Final regulations expand tax safe harbors for certain common modifications of REMIC-held commercial mortgage loans

  • Sidley Austin LLP
  • -
  • USA
  • -
  • September 23 2009

On September 15, 2009, theTreasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) published T.D. 9463, finalizing regulations (the “New Regulations”) that expand a REMIC’s ability to make certain common modifications to commercial mortgage loans without jeopardizing the REMIC’s tax status or exposing it to prohibited transactions taxes

New revenue procedure expands tax-safe modifications for REMIC-held commercial loans

  • Sidley Austin LLP
  • -
  • USA
  • -
  • September 16 2009

On September 15, 2009, the Treasury Department ("Treasury") and the Internal Revenue Service ("IRS") published Revenue Procedure 2009-45 ("Rev. Proc. 2009- 45”), expanding a REMIC’s ability to modify troubled, commercial loans without jeopardizing the REMIC’s tax status or exposing it to prohibited transaction taxes

Modifying loans under the Treasury’s Home Affordable Modification Program will neither jeopardize holders’ tax status nor implicate prohibited transaction taxes

  • Sidley Austin LLP
  • -
  • USA
  • -
  • April 14 2009

On April 10, 2009, the Internal Revenue Service (“IRS”) released Notice 2009-36 and Rev. Proc. 2009-23, which conclude that loan modifications made pursuant to the Home Affordable Modification Program (“HAMP”) will neither jeopardize the special tax status of securitization vehicles holding the modified mortgages nor cause the imposition of any prohibited transaction taxes

Current Search

Suggested Facets

Author

Workarea

© Copyright 2006-2013 Globe Business Publishing Ltd | Cookies | Disclaimer | Privacy policy