New Guidance on Treatment of Public-Private Investment Funds Investment Management Update
Author: Kenneth M. Kess.; Lisa V. Shields.; Jennifer Seyboth.
Source: Volume 27, Number 02, Winter 2010 , pp.87-91(5)
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Abstract:
Recently, the Internal Revenue Service (IRS) issued two revenue procedures that provide guidance relating to the Public-Private Investment Program (PPIP). In Rev. Proc. 2009-38, the IRS sets out the conditions under which Public-Private Investment Funds (“PPIP Funds”) will not be considered taxable mortgage pools (TMPs) for purposes of Section 7701(i). The IRS also issued Rev. Proc. 2009-42, providing the conditions under which a RIC that holds a partnership interest in a PPIP Fund is treated, for purposes of the Section 851(b)(3) asset diversification test (ADT), as if it directly invested in the assets held by the PPIP Fund.Keywords:
Affiliations:
1: Deloitte Tax LLP; 2: Deloitte Tax LLP; 3: Deloitte Tax LLP.