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The notice provides guidance on the applicability of section 108(a)(1)(E)(ii) to the Federal Housing Finance Agency's PRMP or HAMP programs. The notice concludes that if a mortgage servicer sends a borrower-homeowner a notice in conjunction with a written trial period plan or opt-out letter under PRMP or HAMP prior to January 1, 2017; the borrower-homeowner satisfies the trial period terms and conditions; and a permanent modification of the qualified principal residence indebtedness occurs on or after January 1, 2017, the discharge of indebtedness meets the requirements of section 108(a)(1)(E)(ii).
Proposed regulations provide guidance regarding the application of section 514(c)(9)(E) of the Code to partnerships that hold debt-financed real property and have one or more (but not all) qualified tax-exempt organization partners within the meaning of section 514(c)(9)(C).
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