Letter to Treasury and IRS on Rules Regarding Taxable Year of Inclusion

On November 8, MFA submitted a comment letter to Treasury and the IRS on their proposed rules to implement the TCJA changes to section 451(b) of the Internal Revenue Code.  In our letter, we expressed support for the proposed rules, agreeing with Treasury and the IRS that the amendments to section 451(b) made by the Tax Cuts and Jobs Act were not intended to change existing timing and recognition rules with respect to original issue discount and market discount, other than with respect to specified credit card fees.