TAX ISSUES IN SECURITIZATION -
October 1st, 2010
TAX ISSUES IN SECURITIZATION
The basic objective of an ideal tax regime for securitization should be based on the nature of the securitization vehicle.
If the vehicle is merely a passive conduit between the investors and the originator, the conduit should be taxed neutral or tax transparent.
If the conduit amounts to an active framework for re-configuration of the cash flows transferred by the originator, such that the conduit amounts to a virtual satellite company, the conduit should be taxed on entity taxation principles
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