A real estate mortgage investment conduit (REMIC) is "an entity that holds a fixed pool of mortgages and issues multiple classes of interests in itself to investors" under U.S. Federal income tax law and is "treated like a partnership for Federal income tax purposes with its income passed through to its interest holders".[1][2] REMICs are used for the pooling of mortgage loans and issuance of mortgage-backed securities and have been a key contributor to the success of the mortgage-backed securities market over the past several decades.[3]
The federal income taxation of REMICs is governed primarily under 26 U.S.C. §§ 860A–860G of Part IV of Subchapter M of Chapter 1 of Subtitle A of the Internal Revenue Code (26 U.S.C.). To qualify as a REMIC, an organization makes an "election" to do so by filing a Form 1066 with the Internal Revenue Service, and by meeting certain other requirements. They were authorized by the Tax Reform Act of 1986 and introduced in 1987 as the typical vehicle for the securitization of residential mortgages in the United States.[4][5]
- ^ 26 U.S.C. § 860D
- ^ U.S. Master Tax Guide. CCH. 2008. para. 2343 on p. 685. ISBN 9780808019039.
- ^ Lemke, Lins and Picard,Mortgage-Backed Securities, § 4:20 (Thomson West, 2014 ed.).
- ^ Brown, Ellen (October 15, 2010). "Foreclosuregate: Time to Break Up the Too-Big-to-Fail Banks?". YES! Magazine. Retrieved October 19, 2010.
- ^ S.L. Schwarcz, Securitization, Structured Finance and Capital Markets (LexisNexis, 2004), p. 114.
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