News & Analysis as of

REMIC

Crunched Credit

Even If We Don’t Want To, We Should Still Talk About REMIC More 

Crunched Credit on

As regular readers of CrunchedCredit will know, I recently pitched the idea of amending our hoary old REMIC statute to allow additions of collateral after the startup date window to allow modification to performing loans (and...more

Crunched Credit

Let’s Fix REMIC Now!

Crunched Credit on

This title may be a bit ambitious, a triumphalist embrace of hope over experience? But it’s time for the effort to be made....more

Crunched Credit

Time to Fix REMIC:  Grand Bargain Part II

Crunched Credit on

Last week I talked about the Grand Bargain to fix our business. If we’re fixing to fix our business now, we’ve got to talk REMIC. The Real Estate Mortgage Investment Conduit (REMIC) created as part of the Tax Reform Act of...more

Holland & Knight LLP

A Look at the CTA's Subsidiary Exemption as Applied to CMBS Special Purpose Entities

Holland & Knight LLP on

The Corporate Transparency Act (CTA) requires certain domestic and foreign entities, called "reporting companies," to file a beneficial ownership information (BOI) report – which provides information about their owners,...more

Ballard Spahr LLP

CRE CLOs And Distress

Ballard Spahr LLP on

Collateralized loan obligations (CLOs) are securitization vehicles that have traditionally been backed by pools of “bank loans”—senior-secured corporate loans with floating rate coupons. CLOs generally comprise a diverse pool...more

Crunched Credit

Embracing ESG (Carefully)

Crunched Credit on

I really don’t want to talk about ESG.  (Actually, I do but pretend I don’t to bolster my well-earned reputation for balance…Hah!).  ESG is so politically fraught…one person’s lodestar is another shibboleth.  Tribal totem of...more

Cadwalader, Wickersham & Taft LLP

IRS Private Letter Ruling Says CPACE Loans Qualify for REMIC Transactions

The IRS recently concluded that certain commercial property assessed clean energy (“CPACE”) assets are “obligations . . . secured by an interest in real property” under Code Section 860G(a)(3) in a private letter ruling...more

Morgan Lewis

A Guide to the Credit Risk Retention Rules for Securitizations

Morgan Lewis on

On October 21 and 22, 2014, pursuant to the requirements of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the “Dodd-Frank Act”), the Securities and Exchange Commission (the “SEC”) and various federal...more

Proskauer Rose LLP

Proskauer’s Hedge Start: Key Tax Issues

Proskauer Rose LLP on

Different hedge fund investors have different tax concerns that must be taken into account when structuring a hedge fund and its portfolio investments. Hedge fund investors generally fall into three categories:...more

Cadwalader, Wickersham & Taft LLP

Exchange Trust Certificates in REMIC Transactions Qualify as Stripped Bonds or Coupons

On November 24, 2023, the IRS released PLR 202347001, ruling that certificates issued from an “exchange trust” qualify as stripped bonds or stripped coupons within the meaning of Code Section 1286. The taxpayer in the...more

Morgan Lewis

District Court Rules in Favor of RMBS Issuers in Long-Running ERISA Challenge

Morgan Lewis on

The US District Court for the Southern District of New York recently ruled in favor of issuers of residential mortgage-backed securities (RMBS) in a case that was a long-running challenge to the Employee Retirement Income...more

Cadwalader, Wickersham & Taft LLP

No Need to Pretend – Just Extend – if Borrowers Ask to Delay Repayment

Today’s high interest rate environment presents a challenge to many commercial real estate borrowers whose loans are now reaching maturity. Some borrowers are unable to repay their loans, while others are approaching the loan...more

Cadwalader, Wickersham & Taft LLP

Saving Loans for REMICs

Under the REMIC rules, a mortgage loan ceases to be a good REMIC asset if the borrower replaces the real property collateral with government securities (known as defeasance) less than two years after the REMIC’s startup date....more

Kramer Levin Naftalis & Frankel LLP

Final Treasury Regulations Cushion Potential Tax Ramifications of Vanishing LIBOR

On Jan. 4, 2022, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) published final regulations (the Final Regulations) offering guidance to taxpayers with respect to the widely reported...more

Morgan Lewis

Final Treasury Regulations Published on Transition from IBORs to Qualified Rates

Morgan Lewis on

The Internal Revenue Service and the US Treasury Department have issued final regulations providing rules for taxpayers transitioning from interbank offered rates to qualified rates. These regulations provide financial...more

Cadwalader, Wickersham & Taft LLP

IRS Publishes Final IBOR Transition Regulations

On December 30, 2021, the Treasury Department and IRS issued final regulations to address the taxability of modifications that replace LIBOR or another interbank offered rate (an IBOR) with a qualified rate like SOFR....more

McDermott Will & Emery

What Is a QOF?

McDermott Will & Emery on

Since coming into effect in January 2018, Subchapter Z of the US Tax Code—also known as the opportunity zone provisions—has enabled investors to pour billions of dollars into a broad array of businesses, from real estate...more

McDermott Will & Emery

Weekly IRS Roundup September 27 – October 1, 2021

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 27, 2021 – October 1, 2021... September 28, 2021: The IRS released a revenue...more

K&L Gates LLP

COVID-19: Revenue Procedure 2021-12 Extension Of Treatment Of Mortgage Loan Forbearances And Modifications For Mortgage Loans In...

K&L Gates LLP on

Throughout the United States, periodic and ongoing businesses closures and disruptions continue to occur in response to the coronavirus (COVID-19) pandemic. The resulting economic distress has affected borrowers, including...more

McDermott Will & Emery

Weekly IRS Roundup January 11 – January 15, 2021

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 11, 2021 – January 15, 2021... January 11, 2021: The IRS released TD 9948 containing...more

Morgan Lewis

IRS Extends REMIC and Trust Relief Guidance for COVID-19 Emergency-Related Mortgage Forbearances and Modifications

Morgan Lewis on

The Internal Revenue Service (IRS) issued Revenue Procedure 2021-12 on January 14, extending the safe harbors in Revenue Procedures 2020-26 and 2020-34 to September 30, 2021. This LawFlash discusses the portion of Revenue...more

Orrick, Herrington & Sutcliffe LLP

REMICs, Mortgage Loan Modifications and COVID-19

This memorandum discusses certain tax considerations in connection with forbearances, waivers and other modifications with respect to a mortgage loan that is held by a REMIC or about to be contributed to a REMIC, in light of...more

Holland & Knight LLP

IRS Provides Relief for Securitized Mortgage Loan Modifications Anticipated from COVID-19

Holland & Knight LLP on

The Internal Revenue Service (IRS) issued Revenue Procedure 2020-26 on April 13, 2020, providing relief to certain securitization vehicles, including investment trusts and real estate mortgage investment conduits (REMICs),...more

K&L Gates LLP

COVID-19: Revenue Procedure 2020-26 (April 13, 2020) and the CARES Act

K&L Gates LLP on

Treatment of mortgage loan forbearances and modifications for mortgage loans in REMICs and fixed investment trusts - Throughout the United States, state and local governments have ordered various businesses to close in...more

Cozen O'Connor

Tax Issues to Consider in Buying or Holding Distressed Debt

Cozen O'Connor on

In times of economic tumult, many an entrepreneur’s fancy turns to thoughts of acquiring, and profiting from, distressed debt. That is, acquiring debt of highly leveraged companies that are no longer able to service their...more

48 Results
 / 
View per page
Page: of 2

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