rr-19-14.pdf

us-irs-revenue-rulings-rr-19-14rr-19-14.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. 2019-14

This revenue ruling provides various prescribed rates for federal
income tax purposes for June 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. 2019-14 TABLE 1

Applicable Federal Rates (AFR) for June 2019

Period for Compounding
Annual Semiannual Quarterly Monthly

Short-term

AFR 2.37% 2.36% 2.35% 2.35%
110% AFR 2.62% 2.60% 2.59% 2.59%
120% AFR 2.85% 2.83% 2.82% 2.81%
130% AFR 3.09% 3.07% 3.06% 3.05%

Mid-term

AFR 2.38% 2.37% 2.36% 2.36%
110% AFR 2.63% 2.61% 2.60% 2.60%
120% AFR 2.86% 2.84% 2.83% 2.82%
130% AFR 3.10% 3.08% 3.07% 3.06%
150% AFR 3.59% 3.56% 3.54% 3.53%
175% AFR 4.19% 4.15% 4.13% 4.11%

Long-term

AFR 2.76% 2.74% 2.73% 2.72%
110% AFR 3.03% 3.01% 3.00% 2.99%
120% AFR 3.32% 3.29% 3.28% 3.27%
130% AFR 3.59% 3.56% 3.54% 3.53%

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REV. RUL. 2019-14 TABLE 2

Adjusted AFR for June 2019

Period for Compounding
Annual Semiannual Quarterly Monthly
Short-term
adjusted AFR 1.80% 1.79% 1.79% 1.78%

Mid-term
adjusted AFR 1.81% 1.80% 1.80% 1.79%

Long-term
adjusted AFR 2.09% 2.08% 2.07% 2.07%

REV. RUL. 2019-14 TABLE 3

Rates Under Section 382 for June 2019

Adjusted federal long-term rate for the current month 2.09%

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.) 2.19%

REV. RUL. 2019-14 TABLE 4

4
Appropriate Percentages Under Section 42(b)(1) for June 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 7.59%

Appropriate percentage for the 30% present value low-income
housing credit 3.25%

REV. RUL. 2019-14 TABLE 5

Rate Under Section 7520 for June 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 2.8%

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