The IRS has issued a procedure that sets forth conditions under which modifications to the terms of certain commercial mortgage loans that are at risk of default will not cause the IRS to challenge the tax status of certain securitization vehicles (real e

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SUMMARY: The IRS has issued a procedure that sets forth conditions under which modifications to the terms of certain commercial mortgage loans that are at risk of default will not cause the IRS to challenge the tax status of certain securitization vehicles (real estate mortgage investment conduits (REMICs) or investment trusts) that hold the loans or to assert that those modifications give rise to prohibited transactions.

TOPIC: REMICS RICS REITS

SECTION: 860D. REMIC defined

CITATION: Rev. Proc. 2009-45, I.R.B. 2009-40, September 15, 2009

DATE: 2009-09-14

DOC TYPE: Revenue Procedure

EXPLANATION:

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