Excise Taxes on Excess Inclusions of REMIC Residual Interests

Internal Revenue Code (IRC) section 860E(e)(1) provides rules for the taxation of an entity on any transfer of a residual interest in a real estate mortgage investment conduit (REMIC) to a disqualified organization. IRC section 860E(e)(6) provides rules for the taxation of a pass-through entity with interests held by disqualified organizations. Regulations section 1.860E-2(a)(7)(ii) provides rules for the taxation of an entity which waives the tax under section 860E(e)(1).

The latest form for Excise Taxes on Excess Inclusions of REMIC Residual Interests expires 2029-06-30 and can be found here.