26 U.S.C. § 860A: Taxation of REMIC’s

Except as otherwise provided in this part, a REMIC shall not be subject to taxation under this subtitle (and shall not be treated as a corporation, partnership, or trust for purposes of this subtitle). The income of any REMIC shall be taxable to the holders of interests in such REMIC as provided in this part. Except as otherwise provided in this section, the amendments made by this subtitle [subtitle H (§§ 671–675) of title VI of Pub. L. 99–514 , enacting this part and amending sections 582, 593, 856, 1272, 6049, and 7701 of this title] shall take effect on January 1, 1987 . The amendment made by section 672 [amending section 1272 of this title ] shall apply to debt instruments issued after December 31, 1986 , in taxable years ending after such date. The amendment made by section 673 [amending section 7701 of this title ] shall take effect on January 1, 1992 . The amendment made by section 673 shall not apply to any entity in existence on December 31, 1991 . The preceding sentence shall cease to apply with respect to any entity as of the 1st day after December 31, 1991 , on which there is a substantial transfer of cash or other property to such entity. Notwithstanding paragraphs (1) and (2), for purposes of applying section 860F(d) of the Internal Revenue Code of 1986 (as added by this part [this subtitle]), the amendment made by section 673 shall apply to taxable years beginning after December 31, 1986 .”