MARSHALL D. FEIRING is counsel in the firm’s New York office. His practice focuses on fixed investment trusts, real estate investment trusts (“REITs”), real estate mortgage investment conduits (“REMICs”), regulated investment companies, partnerships, investment of sovereign funds, and withholding issues related to notional principal contracts and United States real property interests.
Prior to joining the firm, Mr. Feiring was a Senior Technician Reviewer in the IRS Office of Chief Counsel (Financial Institutions and Products). While with the IRS, he held a series of positions with increasing responsibility and authored or reviewed regulations, revenue rulings, litigation memoranda and private letter rulings concerning a broad range of issues including mortgage and small business loan pass-through trusts, REITs, REMICs (including, regulations concerning the treatment of REMIC residual interests), partnerships, original issue discount, estates and regulated futures contracts. He also worked with the IRS audit function on issues concerning broker-dealers, such as the treatment of dividends, short sales (including the impact of short-sales on tax-exempts) and interest on debt incurred to acquire or carry municipal bonds.
Mr. Feiring is also a co-author of "Revenue Procedure 2010-30 Eases Release of Liens by REMICs in the Case of Commercial Mortgage Loans Secured by Multiple Real Properties," published in Tax Management Real Estate Journal, Vol. 27, No.1, (January 5, 2011).