Section 860E(e) imposes an excise tax on the transfer of a residual interest in a REMIC to a disqualified party. The tax must be paid by the transferor of a pass-thru entity of which the disqualified party is an interest holder.
The latest form for TD 8458, Real Estate Mortgage Investment Conduits expires 2022-10-31 and can be found here.
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Supporting Statement A |