SubChapter M Tax: REITs investment in a REMIC treated as a real estate asset

SubChapter M Tax: REITs investment in a REMIC treated as a real estate asset:

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Exchange-Traded Notes: IRS Fires a Shot Across the Bow of “Wait and See” Taxation | Publications | Morrison Foerster

Exchange-Traded Notes: IRS Fires a Shot Across the Bow of “Wait and See” Taxation | Publications | Morrison Foerster:

“Exchange-Traded Notes: IRS Fires a Shot Across the Bow of ‘Wait and See’ Taxation
Thomas Humphreys and Remmelt Reigersman
12/13/2007
Client Alert
On December 7, 2007 the Internal Revenue Service (“IRS”) and the Treasury Department (“Treasury”) published Revenue Ruling 2008-1 (“Ruling”) [1] and Notice 2008-2 (“Notice”) [2] addressing the U.S. federal income tax treatment of prepaid forward contracts which include certain exchange-traded notes (“ETNs”).

Viewed together, the Ruling and the Notice serve as a warning that the IRS is focused on whether the market’s “wait and see” accounting system for ETNs and similar instruments is appropriate.  However, the immediate impact will only be on a narrow class of single currency-linked ETNs.”