Base Offering Circular Multifamily
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Disqualified Organization and the pass-through entity does not have actual knowledge that such
affidavit is false.
If an electing large partnership holds a Residual Security, all interests in the electing
large partnership are treated as held by disqualified organizations for purposes of the tax imposed
upon a pass-through entity by section 860E(e) of the Code. An exception to this tax, otherwise
available to a pass-through entity that is furnished certain affidavits by record holders of interests
in the entity and that does not know such affidavits are false, is not available to an electing large
partnership.
The Code and the REMIC Regulations also require that reasonable arrangements be made
with respect to each REMIC to enable the REMIC to provide the Treasury and the transferor
with information necessary for the application of the one-time tax described above.
Consequently, the applicable Trust Agreement will provide for the Tax Administrator to perform
such information services as may be required for the application of the one-time tax. If a
Residual Holder transfers an interest in a Residual Security in violation of the relevant transfer
restrictions and triggers the information requirement, the Tax Administrator may charge such
Residual Holder a reasonable fee for providing the information.
Special Considerations for Certain Types of Investors
Dealers in Securities. Residual Holders that are dealers in securities should be aware that
the Service has issued final regulations (the Mark to Market Regulations) under section 475 of
the Code relating to the requirement that a securities dealer mark to market securities held for
sale to customers. This mark-to-market requirement applies to all securities of a dealer, except
to the extent that the dealer has specifically identified a security as held for investment. The
Mark to Market Regulations provide that, for purposes of this mark-to-market requirement, a
Residual Security is not treated as a security and thus may not be marked to market. The Mark
to Market Regulations apply to all Residual Securities acquired on or after January 4, 1995.
Tax-exempt entities. Any excess inclusion income with respect to a Residual Security
held by a tax-exempt entity, including a qualified profit-sharing, pension, or other employee
benefit plan, will be treated as UBTI. Although the legislative history and statutory provisions
imply otherwise, the Treasury conceivably could take the position that, under pre-existing Code
provisions, substantially all income on a Residual Security (including non-excess inclusion
income) is to be treated as UBTI. See Tax Treatment of Residual SecuritiesTaxation of
Residual Holders.
Individuals and Pass-Through Entities. A Residual Holder who is an individual, trust, or
estate will be able to deduct its allocable share of the fees or expenses relating to servicing the
assets assigned to a Trust REMIC or administering the Trust REMIC under section 212 of the
Code only to the extent that the amount of such fee, when combined with its other miscellaneous
itemized deductions for the taxable year, exceeds 2% of its adjusted gross income. That same
limitation will apply to individuals, trusts, or estates that hold Residual Securities indirectly
through a grantor trust, a partnership, an S corporation, a common trust fund, or a nonpublicly
offered RIC. A nonpublicly offered RIC is a RIC other than one whose shares are
(i) continuously offered pursuant to a public offering, (ii) regularly traded on an established