Loan Mods Won’t Undermine REMIC Status Under New Rules from the IRS
September 25, 2009
The IRS issued new tax rules last week that will make it easier to restructure some at-risk commercial mortgages that are held in commercial MBS trusts structured as real estate mortgage investment conduits. IRS Revenue Procedure 2009-45 describes the conditions under which modifications to the terms of certain commercial mortgages that are at risk of default will not cause the IRS to...