N.Y. Tax Law § 8
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.
N.Y. Tax Law § 8