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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”
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
