CCA on Unified Partnership Audit and Litigation Procecdures

CCA / IRS Private Letter Ruling 201206016

CCA_2011122016091738
6501.08-00
Number: 201206016
Release Date: 2/10/2012
Sent: Tuesday, December 20, 2011 4:09:30 PM

Subject: RE: 872 question

We sort of address it in CC-2009-027, August 21, 2009, Subject: Frequently Asked Questions Regarding The Unified Partnership Audit And Litigation Procedures Set Forth In Sections 6221-6234, page 10, second numbered paragraph, where we say you look to state law.

We basically follow this rule across various aspects of the Code. If you look at the regs under 1.860(F)-4(c), we adopt that position for REMICs.  There is no other answer really. Who else would you get to sign?

——do you know of any other cite?

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Part III – Administrative, Procedural, and Miscellaneous

PURPOSE
This notice provides a safe harbor reporting method that an eligible real estate mortgage investment conduit (REMIC) may use to satisfy its reporting obligations under § 1.860F-4(e)(1)(ii) of the Income Tax Regulations with respect to information regarding REMIC assets that the REMIC must report to residual interest holders on a Schedule Q (Form 1066), Quarterly Notice to Residual Interest Holder of REMIC Taxable Income or Net Loss Allocation (Schedule Q).

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SAFE HARBOR REPORTING METHOD FOR ELIGIBLE REMICS REQUIRED TO REPORT ON SCHEDULE Q INFORMATION WITH RESPECT TO REMIC ASSETS

Part III – Administrative, Procedural, and Miscellaneous

PURPOSE
This notice provides a safe harbor reporting method that an eligible real estate mortgage investment conduit (REMIC) may use to satisfy its reporting obligations under § 1.860F-4(e)(1)(ii) of the Income Tax Regulations with respect to information regarding REMIC assets that the REMIC must report to residual interest holders on a Schedule Q (Form 1066), Quarterly Notice to Residual Interest Holder of REMIC Taxable Income or Net Loss Allocation (Schedule Q).

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Notice 2012-05 provides a safe harbor reporting method that an eligible real estate mortgage investment conduit (REMIC) may use to satisfy its reporting obligations with respect to information regarding REMIC assets that the REMIC must report to residual interest holders.

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