The Tax Management Transfer Pricing Report ™ provides news and analysis on U.S. and international governments’ tax policies regarding intercompany transfer pricing.
IRS unveils guidance on modifications of commercial mortgage loans held by real estate mortgage investment conduits, including final rules (T.D. 9463), expanding the list of allowed loan modifications to include certain modifications that are frequently made to commercial mortgages; Rev. Proc. 2009-45 explaining the conditions under which changes to certain mortgage loans at risk of default will not cause IRS to challenge the tax status of certain securitization vehicles that hold the loans or to assert that those changes lead to prohibited transactions; and Notice 2009-79 soliciting further comment on the need for additional guidance.
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