Base Offering Circular - Multifamily 482090 48 The Holder of an MX Class must account separately for each interest in a Regular Class (there may be only one such interest).  Where the interest represents a pro rata part of a Regular Class, the Holder of an MX Class should account for such interest as described under “—Tax Treatment of Regular Securities” above.  Where the interest represents beneficial ownership of a disproportionate part of the principal and interest payments on a Regular Class (a “Strip”), the Holder will be treated as owning, pursuant to section 1286 of the Code, “stripped bonds” to the extent of its share of principal payments and “stripped coupons” to the extent of its share of interest payments on such Regular Class.  Although the tax treatment of a Strip is unclear, the Tax Administrator intends to treat each Strip as a single debt instrument for purposes of information reporting.  The Internal Revenue Service, however, could take a different position. For example, the Internal Revenue Service could contend that a Strip should be treated as a pro rata part of the Regular Class to the extent that the Strip represents a pro rata portion thereof, and “stripped bonds” or “stripped coupons” with respect to the remainder.  An investor should consult its tax advisor regarding this matter. A Holder of an MX Class should calculate original issue discount with respect to each Strip and include it in ordinary income as it accrues, which may be prior to the receipt of cash attributable to such income, in accordance with a constant interest method that takes into account the compounding of interest.  See “Tax Treatment of Regular Securities—Original Issue Discount” above.  The Holder should determine its yield to maturity based on its purchase price allocated to the Strip and on a schedule of payments projected using a prepayment assumption, and then make periodic adjustments to take into account actual prepayment experience.  With respect to a particular Holder, it is not clear whether the prepayment assumption used to calculate original issue discount would be determined at the time of purchase of the Strip or would be the original prepayment assumption with respect to the related Regular Class. If OID accruing with respect to a Strip, computed as described above, is negative for any period, the MX Holder will be entitled to offset such amount only against future positive OID accruing from such Strip, and the Tax Administrator intends to report income in all cases in this manner.  Although not entirely free from doubt, such a Holder may be entitled to deduct a loss to the extent that its remaining basis would exceed the maximum amount of future payments to which the Holder is entitled with respect to such Strip, assuming no further prepayments of the Mortgages (or, perhaps, assuming prepayments at a rate equal to the prepayment assumption with respect to the related Regular Class).  Although the issue is not free from doubt, all or a portion of such loss may be treated as a capital loss if the Strip is a capital asset in the hands of the Holder.  An investor should consult its tax advisor regarding this matter. An MX Holder will realize gain or loss on the sale of a Strip in an amount equal to the difference between the amount realized and its adjusted basis in such Strip.  The seller’s adjusted basis generally is equal to the seller’s allocated cost of the Strip, increased by income previously included, and reduced (but not below zero) by distributions previously received.  Except as described below, any gain or loss on such sale will be capital gain or loss if the MX Holder has held its interest as a capital asset and will be long-term if the interest has been held for the long- term capital gain holding period (more than one year).  Such gain or loss will be ordinary income or loss (i) for a bank or thrift institution or (ii) to the extent income recognized by the Holder is