RR-2018-24

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IRS GuideWire August 17, 2018

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Issue Number:    RR-2018-24

Inside This Issue


Revenue Ruling 2018-24 provides guidance on the tax treatment of the exchange of mortgage-backed securities issued by the Federal Home Loan Mortgage Corporation (Freddie Mac) pursuant to a Single Security Initiative.  Freddie Mac and the Federal National Mortgage Association (Fannie Mae) are both regulated by Federal Housing Finance Agency (FHFA), which has proposed the standardization of the terms for mortgage pass-through certificates issued by Freddie Mac and Fannie Mae.  Accordingly, as part of the FHFA’s Single Security Initiative, the FHFA will require Freddie Mac to cease issuing participation certificates and Fannie Mae to cease issuing mortgage-backed securities, and will require both entities to issue Uniform Mortgage-Backed Securities instead. The revenue ruling provides that the exchange of mortgage-backed securities pursuant to the Single Security Initiative does not constitute a taxable exchange for purposes of section 1001.

It will appear in IRB 2018-36 dated Sept. 4, 2018.

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