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IRS Eases Loan Modification Rules for REMICs

New IRS Guidance on Commercial Mortgage Loan Modifications Loosen Tax Rules; Contractual Restrictions Remain

Ballard Spahr
October 15, 2009

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Final Regulations and New Guidance Regarding Loan Modifications for REMICs Holding Commercial Mortgage Loans

Blank Rome
October 2009

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IRS Addresses CMBS Pre-Default Loan Modification Rules...But Will It Help?

Bingham
October 13, 2009

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New Rules Intended to Facilitate Commercial Real Estate Loan Modifications

Pillsbury
October 6, 2009

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New REMIC Regulations on Modifications of Commercial Loans and Related IRS Revenue Procedure

Kaye Scholer
October 6, 2009

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IRS Announces New REMIC Rules

Seyfarth Shaw
September 29, 2009

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A Compelling New Opportunity For Real Estate Borrowers

Proskauer Rose
September 2009

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Final Regulations Expand Tax Safe Harbors for Certain Common Modifications of REMIC-Held Commercial Mortgage Loans

Sidley Austin
September 23, 2009

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U.S. Treasury Department Permits More Modifications for Securitized Commercial Mortgages

Duane Morris
September 23, 2009

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IRS issues guidance regarding modifications of mortgages held by REMICs and investment trusts

Ashurst
September 2009

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U.S. Department of the Treasury and IRS Issue New Guidance Allowing for Easier Restructuring of CMBS Loans

Ropes & Gray
September 22, 2009

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IRS and Treasury Issue Guidance for Modification of Securitized Commercial Mortgages

Katten
September 22, 2009

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Rev. Proc. 2009-45 Does it help?

Kilpatrick Stockton
September 22, 2009

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Guidance for REMIC Mortgage Modifications

Bryan Cave
September 18, 2009

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Updated REMIC Regulations - What do they mean?

Kilpatrick Stockton
September 18, 2009

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IRS Guidance on Modifications of Securitized Commercial Mortgage Loans Provides New Flexibility and Also Imposes New Requirements

Paul Hastings
September 18, 2009

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IRS Removes Roadblock to Modifying Securitized Loans

Holland & Knight
September 17, 2009

IRS Issues Final REMIC Regulations and Additional Guidance for Commercial Mortgage Loan Modifications

Alston + Bird
September 16, 2009

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Treasury Issues New Rules to Encourage CMBS Workouts

Gibson, Dunn & Crutcher
September 17, 2009

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New IRS Guidance Encourages RIC Investment in TARP Public-Private Partnerships

Ballard Spahr
September 17, 2009

Please see our Hot Topics for more on the PPIP.

Please see our Hot Topics for more on REMIC Relief.

Treasury Department Guidance Issued on Modification of Securitized Commercial Mortgage Loans

Cadwalader
September 17, 2009

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IRS Issues Final Regulations Request for Comments and Additional Guidance on CMBS Loan Modifications

Orrick
September 18, 2009

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New IRS Tax Rules Will Promote Ability to Modify CMBS Loans

Quarles & Brady
September 2009

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Commercial Mortgage Modifications: IRS Guidance on Modifications of Commercial Mortgages Held by Real Estate Mortgage Investment Conduits and Fixed Investment Trusts

Sullivan & Cromwell
September 16, 2009

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REMIC Reform Proposals Intended to Ease Effects of Stalled Credit Markets

Pillsbury
June 29, 2009

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New Revenue Procedure Expands Tax-Safe Modifications for REMIC-Held Commercial Loans

Sidley Austin
September 16, 2009

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Relaxed REMIC Requirements: IRS and Treasury Efforts to Address the Subprime Mortgage Crisis

McDermott, Will & Emery
October 16, 2008
This Alert looks at the recent actions taken by the Internal Revenue Service and U.S. Department of the Treasury to reduce tax risks for real estate mortgage investment conduits (or “REMICs”) that try to minimize foreclosures through loan modifications. Prior to these actions, loan modifications could threaten a REMIC’s beneficial tax status (effectively expose it to double taxation), obviously a disincentive to take actions that could otherwise be beneficial to mortgage holders.

Please see our Hot Topics for more on this subject.

IRS Will Not Challenge REMIC Status for Certain Loan Modifications Made in Connection with the Home Affordable Modification Program

Alston + Bird
April 13, 2009

Please see our Hot Topics for more on "HAMP."

Please see our Hot Topics for more on REMIC relief.

Hot Topics:Tax

Changes in Tax Law; IRS Rules & Guidance
•	Tax Provisions in Health Care Reform Legislation
•	Codification of the Economic Substance Doctrine
•	IRS Rule Would Require Reporting of Uncertain Tax Positions
•	IRS Targets Total Return Swaps
•	Obama Administration's FY2011 Budget & Greenbook
•	Obama Administration's FY2010 Revenue Proposals (The Greenbook)
•	Foreign Account Tax Compliance Act of 2009
•	IRS Guidance On Loan Origination By Foreign Entities
•	Obama Administration's Proposals on International Taxation
•	Proposed Tax Treatment of "Carried Interests"
•	Spin-Offs, Section 355 and "Hot Stock" Rules
•	IRS's New Model 402(f) Notices & Safe Harbor Language
•	Proposed "Stop Tax Haven Abuse Act"
•	IRS's "Substantial Contribution" Test for CFCs
•	Form 990: Annual Report for Charities/Non-Profits
•	Tax: Partnership Debt-for-Equity Exchanges
Tax, IRS & The Crisis
•	Stimulus Bill & Cancellation of Debt Income (CODI)
•	IRS Eases Loan Modification Rules for REMICs
•	IRS Relief for REITs
•	Debt Issuers Get Break on AHYDOs
•	IRS Section 457A: Deferred Offshore Income
•	Using Net Operating Losses (NOLs)
Disputes & Litigation
•	Quality Stores: FICA Tax on Severance Payments?
•	Xilinx & Cost Sharing of Employee Stock Options
•	*IRS Loses Veritas* Cost-sharing Litigation**
•	Eshelman, Title VII & Increased Tax Liability
•	Textron & The Work Product Doctrine
Individual/Personal Tax Issues
•	Estate Tax Legislation
•	Roth IRA Conversion Opportunity
•	IRS's Penalty Framework For Offshore Accounts
•	Report of Foreign Bank and Financial Accounts (FBAR)

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IRS Eases Loan Modification Rules for REMICs

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