rr-19-08.pdf

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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. 2019-08

This revenue ruling provides various prescribed rates for federal
income tax purposes for April 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. 2019-08 TABLE 1

Applicable Federal Rates (AFR) for April 2019

Period for Compounding
Annual Semiannual Quarterly Monthly

Short-term

AFR 2.52% 2.50% 2.49% 2.49%
110% AFR 2.77% 2.75% 2.74% 2.73%
120% AFR 3.02% 3.00% 2.99% 2.98%
130% AFR 3.28% 3.25% 3.24% 3.23%

Mid-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%
150% AFR 3.84% 3.80% 3.78% 3.77%
175% AFR 4.48% 4.43% 4.41% 4.39%

Long-term

AFR 2.89% 2.87% 2.86% 2.85%
110% AFR 3.18% 3.16% 3.15% 3.14%
120% AFR 3.47% 3.44% 3.43% 3.42%
130% AFR 3.76% 3.73% 3.71% 3.70%

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REV. RUL. 2019-08 TABLE 2

Adjusted AFR for April 2019

Period for Compounding
Annual Semiannual Quarterly Monthly
Short-term
adjusted AFR 1.91% 1.90% 1.90% 1.89%

Mid-term
adjusted AFR 1.93% 1.92% 1.92% 1.91%

Long-term
adjusted AFR 2.19% 2.18% 2.17% 2.17%

REV. RUL. 2019-08 TABLE 3

Rates Under Section 382 for April 2019

Adjusted federal long-term rate for the current month 2.19%

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.) 2.20%

REV. RUL. 2019-08 TABLE 4

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Appropriate Percentages Under Section 42(b)(1) for April 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. 2019-08 TABLE 5

Rate Under Section 7520 for April 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 3.0%