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. [...]Read more
Missing piece to CARES? Our Federal Tax Group excavates this missing piece and investigates how it would have restored what was repealed by the Tax Cuts and Jobs Act.
Restoration of Section 958(b)(4)
New Section 951B
A newly minted controlled foreign corporation (CFC) regime
Ready full advisory here. [...]Read more