News & Analysis as of August 16, 2025

Loans

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The term "mortgage" typically refers to a mortgage loan. A mortgage loan is a financing instrument where an individual or business borrows money to purchase property (usually real property) and... more +

Norwich v. Comm’r: Private Credit Firm Prevails in Tax Dispute to Reverse Over-Reported Income

Pillsbury Winthrop Shaw Pittman LLP on 5/20/2025

In Norwich v. Comm’r, the taxpayer mistakenly received $7.5 million[2] as a result of various bank errors between 2007 and 2014. Not knowing that the cash was incorrectly released to it, the taxpayer reported those amounts as...more

IRS Private Letter Ruling Says CPACE Loans Qualify for REMIC Transactions

Cadwalader, Wickersham & Taft LLP on 7/25/2024

The IRS recently concluded that certain commercial property assessed clean energy (“CPACE”) assets are “obligations . . . secured by an interest in real property” under Code Section 860G(a)(3) in a private letter ruling...more

Exchange Trust Certificates in REMIC Transactions Qualify as Stripped Bonds or Coupons

Cadwalader, Wickersham & Taft LLP on 12/21/2023

On November 24, 2023, the IRS released PLR 202347001, ruling that certificates issued from an “exchange trust” qualify as stripped bonds or stripped coupons within the meaning of Code Section 1286. The taxpayer in the...more

Mortgage or other Third Party Loan Investments in Your Plan? Do they Pass Muster under IRS Issue Snapshot?

Pullman & Comley - Labor, Employment and... on 8/31/2022

The IRS Issue Snapshot-Third Party Loans from Plans dated August 23, 2022 is a short advice document for examiners to use when auditing tax-qualified retirement plans that invest in mortgages or other third party loans. IRS...more

The Taxpayer First Act and the Impact on Secondary Market Participants

Mayer Brown on 2/12/2020

The Taxpayer First Act (the “Act” or “TFA”) imposes new limits on the disclosure of US taxpayer tax information obtained on or after December 28, 2019. The Act is designed, among other things, to overhaul and modernize...more

Recent Legislative Developments Will Create Headaches and Increase Financial Risks for Mortgage Servicers and Originators

K&L Gates LLP on 7/27/2015

Two recent legislative developments, which have largely gone unnoticed, will dramatically raise the stakes for mortgage servicers and originators who file IRS Forms 1098. First, the Trade Preferences Extension Act of 2015,...more

IRS Ruling Addresses LLC Eligibility for Cancellation of Debt Exception

Goulston & Storrs PC on 6/22/2015

In new CCA 201525010, the IRS addressed the issue of whether a general “exculpatory” debt of an LLC is recourse or non-recourse for purposes of classifying debt-relief as potential cancellation of debt (COD) income. Recourse...more

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