rr-19-07.pdf

us-irs-revenue-rulings-rr-19-07rr-19-07.pdfGuidance

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Section 1274.--Determination of Issue Price in the Case of Certain Debt Instruments
Issued for Property

(Also Sections 42, 280G, 382, 467, 468, 482, 483, 1288, 7520, 7872.)

Rev. Rul. 2019-07

This revenue ruling provides various prescribed rates for federal
income tax purposes for March 2019 (the current month). Table 1
contains the short-term, mid-term, and long-term applicable federal rates
(AFR) for the current month for purposes of section 1274(d) of the Internal
Revenue Code. Table 2 contains the short-term, mid-term, and long-term
adjusted applicable federal rates (adjusted AFR) for the current month for
purposes of section 1288(b). Table 3 sets forth the adjusted federal long-
term rate and the long-term tax-exempt rate described in section 382(f).
Table 4 contains the appropriate percentages for determining the low-
income housing credit described in section 42(b)(1) for buildings placed in
service during the current month. However, under section 42(b)(2), the
applicable percentage for non-federally subsidized new buildings placed in
service after July 30, 2008, shall not be less than 9%. Finally, Table 5
contains the federal rate for determining the present value of an annuity,
an interest for life or for a term of years, or a remainder or a reversionary
interest for purposes of section 7520.

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REV. RUL. 2019-07 TABLE 1

Applicable Federal Rates (AFR) for March 2019

Period for Compounding
Annual Semiannual Quarterly Monthly

Short-term

AFR 2.55% 2.53% 2.52% 2.52%
110% AFR 2.80% 2.78% 2.77% 2.76%
120% AFR 3.06% 3.04% 3.03% 3.02%
130% AFR 3.32% 3.29% 3.28% 3.27%

Mid-term

AFR 2.59% 2.57% 2.56% 2.56%
110% AFR 2.85% 2.83% 2.82% 2.81%
120% AFR 3.10% 3.08% 3.07% 3.06%
130% AFR 3.37% 3.34% 3.33% 3.32%
150% AFR 3.90% 3.86% 3.84% 3.83%
175% AFR 4.55% 4.50% 4.47% 4.46%

Long-term

AFR 2.91% 2.89% 2.88% 2.87%
110% AFR 3.21% 3.18% 3.17% 3.16%
120% AFR 3.50% 3.47% 3.46% 3.45%
130% AFR 3.80% 3.76% 3.74% 3.73%

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REV. RUL. 2019-07 TABLE 2

Adjusted AFR for March 2019

Period for Compounding
Annual Semiannual Quarterly Monthly
Short-term
adjusted AFR 1.93% 1.92% 1.92% 1.91%

Mid-term
adjusted AFR 1.96% 1.95% 1.95% 1.94%

Long-term
adjusted AFR 2.20% 2.19% 2.18% 2.18%

REV. RUL. 2019-07 TABLE 3

Rates Under Section 382 for March 2019

Adjusted federal long-term rate for the current month 2.20%

Long-term tax-exempt rate for ownership changes during the
current month (the highest of the adjusted federal long-term
rates for the current month and the prior two months.) 2.39%

REV. RUL. 2019-07 TABLE 4

4
Appropriate Percentages Under Section 42(b)(1) for March 2019
Note: Under section 42(b)(2), the applicable percentage for non-federally subsidized
new buildings placed in service after July 30, 2008, shall not be less than 9%.

Appropriate percentage for the 70% present value low-income
housing credit 7.63%

Appropriate percentage for the 30% present value low-income
housing credit 3.27%

REV. RUL. 2019-07 TABLE 5

Rate Under Section 7520 for March 2019

Applicable federal rate for determining the present value of an
annuity, an interest for life or a term of years, or a remainder or
reversionary interest 3.2%

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