April 20, 2020

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 to, and held in, real estate mortgage investment conduits (REMICs) and grantor trusts without jeopardizing these vehicles’ U.S. tax status.

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This flow chart illustrates when a loan qualifies for inclusion in a REMIC under the IRS’ new coronavirus guidance. For more information about the guidance, click here.

The UK has introduced a number of tax measures in response to the COVID-19 pandemic. We discuss those measures here.

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New guidance clarifies net operating loss carryback rules.

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A coronavirus-related delay in recording a mortgage should not prevent a mortgage loan from being REMIC-eligible.

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The IRS will allow partnerships to file amended returns to take advantage of CARES Act tax benefits.

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IRS office closures due to COVID-19 may be preventing foreign entities from obtaining new EINs.  Read about it here.

The IRS recently issued its first private letter ruling approving a tax-deferred spinoff of a non-income collecting trade or business. 

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