SECTION 27. REAL ESTATE

MORTGAGE INVESTMENT CONDUIT (REMIC) (§§ 860A–860G)

.01 REMIC inducement fees .

(1) Description of change . A taxpayer that receives an inducement fee in connection with becoming the holder of a noneconomic residual interest in a REMIC must take that fee into account over the remaining expected life of the applicable REMIC in accordance with § 1.446–6. This change applies to a taxpayer that seeks to change from any method of accounting for such inducement fees to one of the safe harbor methods provided under § 1.446–6(e)(1) – (2). See Rev. Proc. 2004–30, 2004–1 C.B. 950, for additional guidance relating to this change.

(2) Manner of making change . A taxpayer making this change must identify the specific safe harbor method under § 1.446–(6)(e) to which the taxpayer is changing.

(3) Designated automatic accounting method change number . The designated automatic accounting method change number for a change under section 27.01 of this APPENDIX is “79.” See section 6.02(4) of this revenue procedure.

(4) Contact information . For further information regarding a change under this section, contact Santina Jannotta at 202–622–3930 (not a toll-free call).

.02 Reserved .