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
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
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