rr-22-01.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, 7702, 7872.)

Rev. Rul. 2022-1

This revenue ruling provides various prescribed rates for federal income tax
purposes for January 2022 (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
sect ion 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%. 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. Table 6 contains the deemed rate of return for transfers made during
calendar year 2022 to pooled income funds described in section 642(c)(5) that have
been in existence for less than 3 taxable years immediately preceding the taxable year
in which the transfer was made. Finally, Table 7 contains the average of the applicable
federal mid-term rates (based on annual compounding) for the 60-month periods ending
December 31, 2019, December 31, 2020, and December 31, 2021, for purposes of
section 7702(f)(11).

2

REV. RUL. 2022-1 TABLE 1

Applicable Federal Rates (AFR) for January 2022

Period for Compounding
Annual Semiannual Quarterly Monthly

Short-term

AFR 0.44% 0.44% 0.44% 0.44%
110% AFR 0.48% 0.48% 0.48% 0.48%
120% AFR 0.53% 0.53% 0.53% 0.53%
130% AFR 0.57% 0.57% 0.57% 0.57%

Mid-term

AFR 1.30% 1.30% 1.30% 1.30%
110% AFR 1.44% 1.43% 1.43% 1.43%
120% AFR 1.57% 1.56% 1.56% 1.55%
130% AFR 1.70% 1.69% 1.69% 1.68%
150% AFR 1.96% 1.95% 1.95% 1.94%
175% AFR 2.29% 2.28% 2.27% 2.27%

Long-term

AFR 1.82% 1.81% 1.81% 1.80%
110% AFR 2.00% 1.99% 1.99% 1.98%
120% AFR 2.18% 2.17% 2.16% 2.16%
130% AFR 2.36% 2.35% 2.34% 2.34%

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REV. RUL. 2022-1 TABLE 2

Adjusted AFR for January 2022

Period for Compounding
Annual Semiannual Quarterly Monthly
Short-term
adjusted AFR 0.33% 0.33% 0.33% 0.33%

Mid-term
adjusted AFR 0.99% 0.99% 0.99% 0.99%

Long-term
adjusted AFR 1.37% 1.37% 1.37% 1.37%

REV. RUL. 2022-1 TABLE 3

Rates Under Section 382 for January 2022

Adjusted federal long-term rate for the current month 1.37%

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.) 1.45%

REV. RUL. 2022-1 TABLE 4

Appropriate Percentages Under Section 42(b)(1) for January 2022
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 7.36%

Appropriate percentage for the 30% present value low-income
housing credit 3.15%

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REV. RUL. 2022-1 TABLE 5

Rate Under Section 7520 for January 2022

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 1.6%

REV. RUL. 2022-1 TABLE 6

Deemed Rate for Transfers to Pooled Income Funds During 2022

Deemed rate of return for transfers during 2022 to pooled income
funds that have been in existence for less than 3 taxable years 1.6%

REV. RUL. 2022-1 TABLE 7

Average of the Applicable Federal Mid-Term Rates for 2019, 2020, 2021

For purposes of section 7702(f)(11), the average of the applicable federal mid-term
rates (based on annual compounding) for the 60-month periods ending December 31,
2019, December 31, 2020, and December 31, 2021, are:

60-month period ending December 31, 2019 2.00% rounded to 2%

60-month period ending December 31, 2020 1.82% rounded to 2%

60-month period ending December 31, 2021 1.72% rounded to 2%