The US Treasury Department and Internal Revenue Service (IRS) have issued temporary and proposed regulations on the treatment of income from US Real Estate Mortgage Investment Conduits (REMICs) that is allocated to foreign persons. The regulations address the tax consequences to foreign persons who hold residual interests in US REMICs as partners in domestic partnerships, shareholders of real estate investment trusts (REITs), shareholders of regulated investment companies (RICs), participants in common trust funds, and patrons of Subchapter T cooperatives. According to the preamble to the regulations, the timing of income recognized for US withholding tax purposes will be accelerated to...