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Modifications & Tax Issues - Research
April 10, 2009
Mortgage Modification Safe-Harbors?
HAMP, Are We There Yet?
The Silent Modification Killers:
Sanctity of Contract, The 100% Tax, The Lawsuit!
New Insured Tradable Principal Reduction Modifications
New Treasury/IRS Notice 2009-36 and Rev. Proc. 2009-23 (Step 3)
By Richard Ivar Rydstrom, Esq., LL.M.
Chairman, Coalition for Mortgage Industry Solutions,
Pro Council Advisory
rich@procouncil.com
IRS / Treasury
Title 26--Internal Revenue
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CHAPTER I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY (CONTINUED)
PART 1--INCOME TAXES
1.860A-0 Outline of REMIC provisions.
1.860A-1 Effective dates and transition rules.
1.860A-1T Effective dates and transition rules (temporary).
1.860C-1 Taxation of holders of residual interests.
1.860C-2 Determination of REMIC taxable income or net loss.
1.860D-1 Definition of a REMIC.
1.860E-1 Treatment of taxable income of a residual interest holder in excess of daily accruals.
1.860E-2 Tax on transfers of residual interests to certain organizations.
1.860F-1 Qualified liquidations.
1.860F-2 Transfers to a REMIC.
1.860F-4 REMIC reporting requirements and other administrative rules.
1.860G-1 Definition of regular and residual interests.
1.860G-2 Other rules.
1.860G-3 Treatment of foreign persons.
1.860G-3T Treatment of foreign persons (temporary).
Comments for Rev Proc 2008-28
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