Following the collapse of the non-agency market, critics of banks have suggested that MBS issuers could be liable for significant tax payments due to violations of real estate mortgage investment conduit rules. However, the IRS has yet to act on the issue and officials at the IRS downplayed suggestions of a wide-scale investigation. REMICs receive tax advantages as passive, static investments. The IRS requires that mortgages be transferred to the trust within a certain timeframe, usually within 90 days after the trust is created. Some have suggested that the improper assignment of mortgages to REMICs is...