Alston & Bird Tax Blog

IRS Issues COVID-19 Forbearance Guidance for REMICs and Investment Trusts

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Yesterday, our Federal Tax Group discussed a new Revenue Procedure from the IRS that provides useful real estate mortgage investment conduit (REMIC) and investment trust safe harbors for mortgage loan payment forbearances (and related modifications).

  • What safe harbors are available?
  • Which mortgage loan forbearance programs are eligible?
  • How are “related modifications” treated?

Alston & Bird has formed a multidisciplinary task force to advise clients on the business and legal implications of the coronavirus (COVID-19).

Read the full advisory here.

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About Daniel Reach

Danny Reach is an associate in the Federal and International Tax Group. His practice includes federal and international tax planning, and he has particular experience with the tax aspects of derivative financial instruments.

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About Clay Littlefield

Clay Littlefield, a partner based out of Alston & Bird’s Charlotte and New York offices, is a member of the Federal & International Tax Group. Clay concentrates his practice on tax issues confronted by underwriters, issuers, and investors participating in structured finance transactions, including mortgage and asset-backed securitizations, REMICs, CLOs, REITs, and similar structures.

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About John Baron

John Baron leads Alston & Bird's Federal & International Tax Group and is the former chair of the firm’s Partners Committee. His practice is principally transactional in nature, and his clients include both domestic and foreign companies and financial institutions, as well as private equity firms, CDOs, and hedge funds.

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