Tax News

CCH (cch.taxgroup.com) reports:

  The IRS has issued guidance that informs trustees and middlemen of widely held fixed investment trusts (WHFITs) that the IRS will not impose penalties under the reporting rules pursuant to Reg. §1.671-5(m) with respect to calendar year 2008. The guidance also informs trustees and middlemen of widely held mortgage trusts (WHMTs) that, pending future published guidance, certain modifications of mortgages held by a WHMT that has entered into a guarantee arrangement are not required to be reported under the WHFIT reporting rules. This guidance is effective September 12, 2008. Trustees and middlemen may apply the reporting exception for certain modifications of mortgages as of January 1, 2007.

  The IRS issued this guidance at the request of middlemen and trustees of WHFITs that require additional time to update their computer and information systems to fully comply with WHFIT reporting rules.

  The IRS requests comments regarding the scope and description of the reporting exception described in the guidance. Comments should be submitted on or before November 1, 2008, and should include a reference to Notice 2008-77.

Notice 2008-77, 2008FED ¶46,567

Other References:

 
Code Sec. 671

  CCH Reference - 2008FED ¶24,686.0525

  CCH Reference - 2008FED ¶24,686.86

  Tax Research Consultant

  CCH Reference - TRC ESTTRST:36,300