Role: Real Estate Mortgage Investment Conduits (REMICs) Consultant - SME
Duration: 3 months
Rate: $90/hr to $150/hr (1099/C2C)
A Large Public Accounting Firm is seeking a Director or PPMD level Tax Consultant to help w/ Real Estate Mortgage Investment Conduits (REMICs). This individual would have a lead role in the tax aspects for REMICs and function as a Subject Matter Expert in this setting.
REMICs were created as part of the Tax Reform Act of 1986 (TRA). The TRA Conference Report states that the REMIC was created as the exclusive means of issuing multiple-class, real estate mortgage-backed securities without the imposition of two levels of tax. The IRS describes a REMIC as an entity formed for the purpose of holding a fixed pool of mortgages secured by interests in real property (IRS Publication 550, Investment Income and Expenses, 2015). A REMIC is generally treated as a partnership, the income or loss from which is not treated as income or loss from a passive activity. REMICs issue regular interests (treated as debt instruments) and residual interests (treated as partnership interests). A REMIC may issue several classes (tranches) of regular interests but may issue only one class of residual interests.
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