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Articles 1 - 4 of 4
Full-Text Articles in Law
Beneficial Ownership And The Remic Classification Rules, Bradley T. Borden, David J. Reiss
Beneficial Ownership And The Remic Classification Rules, Bradley T. Borden, David J. Reiss
Bradley T. Borden
REMICs are securitized pools of mortgages that qualify for special flow-through taxation. To qualify for flow-through tax treatment, the pool must satisfy several requirements. An intended REMIC that fails to satisfy those requirements will likely be taxed as a corporation and payments made to holders of interests in a failed REMIC will likely be nondeductible dividend payments, subjecting the REMIC to significant tax and penalties. Such tax and penalties will cause beneficial interests in the pool to lose value and frustrate investors who relied upon REMIC classification as an incentive to purchase interests. Thus, tax classification is critical to REMICs …
Wall Street Rules Applied To Remic Classification, Bradley T. Borden, David Reiss
Wall Street Rules Applied To Remic Classification, Bradley T. Borden, David Reiss
Bradley T. Borden
Investors in mortgage-backed securities, built on the shoulders of the tax-advantaged Real Estate Mortgage Investment Conduit (“REMIC”), may be facing extraordinary tax losses because of how bankers and lawyers structured these securities. This calamity is compounded by the fact that those professional advisors should have known that the REMICs they created were flawed from the start. If these losses are realized, those professionals will face suits for damages so large that they could put them out of business.
The original paper is available at: http://newsandinsight.thomsonreuters.com/New_York/Insight/2012/09_-_September/Wall_Street_Rules_Applied_to_REMIC_Classification/.
The Overlap Of Tax And Financial Aspects Of Real Estate Ventures, Bradley T. Borden
The Overlap Of Tax And Financial Aspects Of Real Estate Ventures, Bradley T. Borden
Bradley T. Borden
This article examines the effect partnership tax law has on financial aspects of real estate ventures. It introduces the relevance of the aggregate and entity views of tax partnerships (i.e., LLCs, LPs, and other partnerships) and demonstrates how those views can greatly affect financial projections for each of the members of a real estate venture. It also demonstrates how financial calculations can vary significantly depending upon how closely analysts track a tax partnership’s allocation method. Finally, the article serves as a primer for tax practitioners who are unfamiliar with the financial tools that are so prevalent in real estate analysis, …
From Allocations To Series Llcs: 2011'S Partnership Tax Articles, Bradley T. Borden
From Allocations To Series Llcs: 2011'S Partnership Tax Articles, Bradley T. Borden
Bradley T. Borden
This article reviews the partnership tax articles published in student-edited journals in 2011. The articles comprise a rich output on timely topics and demonstrate that partnership tax is primed for even more scholarly attention.