Base Offering Circular - Multifamily
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Holder would by virtue of its ownership percentage be treated as the Tax Matters Person for the
related Trust REMIC. No successor agent may be appointed without the consent of Ginnie Mae.
Tax Administrator
The Tax Administrator, which may be the same person as the Trustee, generally is
responsible for the federal and state tax administration of the related Trust and the related Trust
REMICs. Foremost among the Tax Administrators duties will be the preparation of the income
tax returns and reports of the related Trust and the related Trust REMICs and the related
underlying tax accounting. Additional information about the duties and activities of the Tax
Administrator is set forth in Certain Federal Income Tax Consequences.
REMIC Reporting
Each Trust Agreement will require the Tax Administrator to undertake the following
responsibilities, among others in respect of the related Trust:
(a)
to cause elections to be made with respect to each related Asset Pool to be treated
as a REMIC;
(b)
to prepare and cause to be filed annually, on a calendar year basis, Form 1066,
U.S. Real Estate Mortgage Investment Conduit Income Tax Return, Form 8811, and any other
required federal or state tax returns with respect to each related Trust REMIC and the related
Trust;
(c)
to prepare all information reports and returns required to be provided to Holders
under federal or state tax provisions concerning REMICs, including Schedule Q to Form 1066,
and to forward these reports and returns to the appropriate Holders; and
(d)
to pay when due, on behalf of the affected Trust REMIC or the related Trust, the
amount of any federal, state and local taxes imposed thereon, which amount generally will be
paid from assets of the related Trust.
Ginnie Mae does not guarantee the accuracy or timeliness of the tax administration and
reporting.
CERTAIN FEDERAL INCOME TAX CONSEQUENCES
The following discussion, prepared by Ginnie Maes Legal Advisor, is a summary of the
anticipated material federal income tax consequences of the purchase, ownership, and disposition
of the Securities. The summary is based upon laws, regulations, rulings, and decisions now in
effect, all of which are subject to change. The discussion does not purport to deal with the
federal income tax consequences to all categories of investors, some of which may be subject to
special rules. The discussion focuses primarily on investors who will hold the Securities as
capital assets (generally, property held for investment) within the meaning of section 1221 of
the Code, although much of the discussion is applicable to other investors as well. Investors