Subprime Loan Modifications and Tax Implications


The federal government took a major step in implementing its program for alleviating the subprime mortgage crisis when the Internal Revenue Service, on December 26, 2007, issued Revenue Procedure 2007-72. In its pronouncement, the IRS has said that it will not seek to disqualify a REMIC (that is, a real estate mortgage investment conduit, under Internal Revenue Code Sec. 860A et. seq.) if a mortgage loan that is included in the REMIC is modified, under the conditions stated in this Revenue Procedure. Also, the IRS will not seek to categorize the loan modification as a ?prohibited transaction? under the REMIC rules.

See full newsletter for more.

LOADING PDF: If there are any problems, click here to download the file.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Manatt, Phelps & Phillips, LLP | Attorney Advertising

Written by:


Manatt, Phelps & Phillips, LLP on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:

Sign up to create your digest using LinkedIn*

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.

Already signed up? Log in here

*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.