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Real estate mortgage investment conduit (REMIC)

Amounts received by REMICs in suit against mortgage sellers had no negative effects

Amounts received by REMICs in suit against mortgage sellers had no negative effects

PLR 201601005 In a private letter ruling, IRS has held that the fact that a group of real estate mortgage investment conduits (REMICs) received a settlement from a suit by some of the REMICs’ investors against the sellers of mortgages to the REMICs, based on breaches of representations and warranties with respect to those mortgages, […]

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Tax Treatment Explained Where Remic Regular Interests Sold and Residual Interest Retained

Tax Treatment Explained Where Remic Regular Interests Sold and Residual Interest Retained

PLR 201517007   In a Technical Advice Memorandum (TAM), IRS has concluded that a parent corporation could take a capital loss from its subsidiary’s sale or exchange of real estate mortgage investment conduit (REMIC) regular interests, while taking an ordinary loss on a retained REMIC residual interest, under Code Sec. 860F(b)(1)(D)(ii) and Reg. § 1.860F-2(b)(4)(iv). […]

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Some ordinary income resulted from sale of impaired REMIC regular interests

Some ordinary income resulted from sale of impaired REMIC regular interests

Legal Advice Issued by Field Attorneys 20144801F In Legal Advice issued by Field Attorneys (LAFA), IRS has concluded that a taxpayer realized some ordinary income from a sale of real estate mortgage investment conduit (REMIC) regular interests for which a partial worthlessness deduction had been taken in a prior tax year. The taxpayer treated the […]

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Meet Paul Raymond

Meet Paul Raymond

Mr. Raymond is a sought after speaker in tax controversy law by many attorney, accountant, and business groups and at the request of the Internal Revenue Service, has presented programs at the IRS Nationwide Tax Forum, attended by tax professionals throughout the United States.

Additionally, he continues to be an active member in the Section of Taxation, American Bar Association, where he was the Past Chair of the Employment Taxes Committee.

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Member CA Bar Member Orange County Bar US Tax Court Attorney