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Loans REMIC Internal Revenue Service

Cadwalader, Wickersham & Taft LLP

IRS Private Letter Ruling Says CPACE Loans Qualify for REMIC Transactions

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

Cadwalader, Wickersham & Taft LLP

Exchange Trust Certificates in REMIC Transactions Qualify as Stripped Bonds or Coupons

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

Cadwalader, Wickersham & Taft LLP

COVID-19 Update: IRS Issues Securitization Guidance on Coronavirus-Related Forbearances

On April 13, 2020, the Internal Revenue Service issued a helpful revenue procedure that permits loans that are subject to certain forbearances and related modifications as a result of the COVID-19 pandemic to be contributed...more

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