SECTION 1. PURPOSE
Internal Revenue Bulletin 2020-26 · 2026-10-03 edition · updated 2026-10-04 · United States
In response to the Coronavirus Disease 2019 (COVID-19) emergency, this revenue procedure describes temporary safe
harbors for the purpose of determining the Federal tax status of certain arrangements that hold real property as trusts. Under the safe harbors, certain modifications to mortgage loans, certain modifications to leases, and certain additional capital contributions are not treated under § 301.7701–4(c) of the Procedure and Administration Regulations as manifesting a power to vary.
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