Base Offering Circular - Multifamily
482090
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associated with holding the residual interest does not exceed the sum of the present values of (i)
any consideration given to the transferee to acquire the interest, (ii) the expected future
distributions on the interest, and (iii) any anticipated tax savings associated with holding the
interest as the REMIC generates losses. For purposes of this calculation, the present values
generally are calculated using a discount rate equal to the applicable federal rate. The New
Proposed Regulations indicate that the effective date of the modification to the safe harbor
requirements could be as early as February 4, 2000.
In addition, on December 8, 2000, the IRS issued Revenue Procedure 2001-12, effective
February 4, 2000 pending finalization of proposed regulations, which expands the safe harbor for
transfers of noneconomic residual interests to include transfers to certain taxable domestic
corporations with significant gross and net assets, provided that those corporations agree to
transfer the residual interests only to other taxable domestic corporations in transactions
qualifying for one of the safe harbor provisions. Eligibility for the expanded safe harbor requires,
among other things, that the transferor not know of any facts or circumstances that reasonably
indicate that the taxes associated with the residual interest will not be paid. The Revenue
Procedure provides that transfers to foreign branches of domestic corporations or transfers
involving arrangements that subject income from the residual interest to net tax by a foreign
country or possession of the United States are not within the safe harbor, and also provides that if
the amount of consideration given to the transferee to acquire the residual interest is so low that
under any set of reasonable assumptions a reasonable person would conclude that the taxes
associated with holding the residual interest will not be paid, then the transferor will be deemed
to know that the transferee cannot or will not pay those taxes.
Ownership of Residual Interests by Disqualified Organizations
The Code contains three sanctions that are designed to prevent or discourage the direct or
indirect ownership of a REMIC residual interest (such as a Residual Security) by the United
States, any state or political subdivision thereof, any foreign government, any international
organization, any agency or instrumentality of any of the foregoing, any tax-exempt organization
(other than a farmers cooperative described in section 521 of the Code) that is not subject to the
tax on UBTI, or any rural electrical or telephone cooperative (each a Disqualified
Organization). A corporation is not treated as an instrumentality of the United States or any
state or political subdivision thereof if all of its activities are subject to tax and, with the
exception of FHLMC, a majority of its board of directors is not selected by such governmental
unit.
First, the REMIC status of any REMIC created after March 31, 1988 is dependent upon
the presence of reasonable arrangements designed to prevent a Disqualified Organization from
acquiring record ownership of a residual interest. Residual Securities are not offered for sale to
Disqualified Organizations. Furthermore, (i) Residual Securities will be registered as to both
principal and any stated interest with the Trustee (or its agent) and transfer of a Residual Security
may be effected only by surrender of the old Residual Security and reissuance by the Trustee of a
new Residual Security to the new Holder, (ii) the applicable Trust Agreement will prohibit the
ownership of Residual Securities by Disqualified Organizations, and (iii) each Residual Security
will contain a legend providing notice of that prohibition. Consequently, each Trust REMIC