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Introduction

SECTION 27. REAL ESTATE

Internal Revenue Bulletin 2015-5 · 2026-10-03 edition · updated 2026-10-04 · United States

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 this section 27.01 is “79.” (4) Contact information . For further information regarding a change under this section, contact John W. Rogers, III at (202) 317-6895 (not a toll-free number).

.02 Reserved .

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