Section 8. Exemption from taxes granted to REMICs

An entity that is
  treated for federal income  tax  purposes  as  a  real  estate  mortgage
  investment  conduit, hereinafter referred to as a REMIC, as such term is
  defined in section 860D of the internal revenue code,  shall  be  exempt
  from  all  taxation  imposed  or authorized under this chapter, upon its
  capital stock, franchises or income. A REMIC shall not be treated  as  a
  corporation,  partnership  or  trust  for  purposes of this chapter. The
  assets of a REMIC shall not  be  included  in  the  calculation  of  any
  franchise  tax  liability  under  this  chapter. This provision does not
  exempt the holders of regular  or  residual  interests,  as  defined  in
  section  860G  of  the  internal revenue code, in a REMIC from tax on or
  measured by such regular or residual interests, or on income  from  such
  interests.
  * NB Applies to taxable years beginning after December 31, 1986