Part I. Rulings and Decisions Under the Internal Revenue Code of 1986

Section 860G.—Other Definitions and Special Rules

This revenue procedure describes the conditions under which changes to certain residential mortgage loans will not cause the Internal Revenue Service to challenge the tax status of certain securitization vehicles holding the loans or to assert that those modifications create a liability for tax on a prohibited transaction. See Rev. Proc. 2008-28, page 1054.

Section 1001.—Determi- nation of Amount of and Recognition of Gain or Loss

26 CFR 1.1001–3: Modifications of debt instruments.

This revenue procedure describes the conditions under which changes to certain residential mortgage loans will not cause the Internal Revenue Service to challenge the tax status of certain securitization vehicles holding the loans or to assert that those modifications create a liability for tax on a prohibited transaction. See Rev. Proc. 2008-28, page 1054.

Section 7701.—Definitions

26 CFR 301.7701–4: Trusts.

This revenue procedure describes the conditions under which changes to certain residential mortgage loans will not cause the Internal Revenue Service to challenge the tax status of certain securitization vehicles holding the loans or to assert that those modifications create a liability for tax on a prohibited transaction. See Rev. Proc. 2008-28, page 1054.

2008–23 I.R.B. 1053 June 9, 2008