§860F. Other rules — Inbound Citations
26 U.S.C. § 860F
Cited by 2 provisions in release 119-102.
Citations to §860F(a)(4)(A)
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(a) For purposes of this title, the terms “real estate mortgage investment conduit” and “REMIC” mean any entity—(1) to which an election to be treated as a REMIC applies for the taxable year and all prior taxable years,(2) all of the interests in which are regular interests or residual interests,(3) which has 1 (and only 1) class of residual interests (and all distributions, if any, with respect to such interests are pro rata),(4) as of the close of the 3rd month beginning after the startup day and at all times thereafter, substantially all of the assets of which consist of qualified mortgages and permitted investments,(5) which has a taxable year which is a calendar year, and(6) with respect to which there are reasonable arrangements designed to ensure that—(A) residual interests in such entity are not held by disqualified organizations (as defined in section 860E(e)(5)), and(B) information necessary for the application of section 860E(e) will be made available by the entity.In the case of a qualified liquidation (as defined in section 860F(a)(4)(A)), paragraph (4) shall not apply during the liquidation period (as defined in section 860F(a)(4)(B)).
Citations to §860F(a)(4)(B)
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(a) For purposes of this title, the terms “real estate mortgage investment conduit” and “REMIC” mean any entity—(1) to which an election to be treated as a REMIC applies for the taxable year and all prior taxable years,(2) all of the interests in which are regular interests or residual interests,(3) which has 1 (and only 1) class of residual interests (and all distributions, if any, with respect to such interests are pro rata),(4) as of the close of the 3rd month beginning after the startup day and at all times thereafter, substantially all of the assets of which consist of qualified mortgages and permitted investments,(5) which has a taxable year which is a calendar year, and(6) with respect to which there are reasonable arrangements designed to ensure that—(A) residual interests in such entity are not held by disqualified organizations (as defined in section 860E(e)(5)), and(B) information necessary for the application of section 860E(e) will be made available by the entity.In the case of a qualified liquidation (as defined in section 860F(a)(4)(A)), paragraph (4) shall not apply during the liquidation period (as defined in section 860F(a)(4)(B)).