excess inclusion
(1) In general The term “excess inclusion” means, with respect to any residual interest in a REMIC for any calendar quarter, the excess (if any) of— (A) the amount taken into account with respect to such interest by the holder under section 860C(a), over (B) the sum of the daily accruals with respect to such interest for days during such calendar quarter while held by such holder. To the extent provided in regulations, if residual interests in a REMIC do not have significant value, the excess inclusions with respect to such interests shall be the amount determined under subparagraph (A) without regard to subparagraph (B).