rr-19-04.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. 2019-04

This revenue ruling provides various prescribed rates for federal
income tax purposes for February 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. 2019-04 TABLE 1

Applicable Federal Rates (AFR) for February 2019

Period for Compounding
Annual Semiannual Quarterly Monthly

Short-term

AFR 2.57% 2.55% 2.54% 2.54%
110% AFR 2.83% 2.81% 2.80% 2.79%
120% AFR 3.08% 3.06% 3.05% 3.04%
130% AFR 3.35% 3.32% 3.31% 3.30%

Mid-term

AFR 2.63% 2.61% 2.60% 2.60%
110% AFR 2.89% 2.87% 2.86% 2.85%
120% AFR 3.15% 3.13% 3.12% 3.11%
130% AFR 3.42% 3.39% 3.38% 3.37%
150% AFR 3.96% 3.92% 3.90% 3.89%
175% AFR 4.62% 4.57% 4.54% 4.53%

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. 2019-04 TABLE 2

Adjusted AFR for February 2019

Period for Compounding
Annual Semiannual Quarterly Monthly
Short-term
adjusted AFR 1.95% 1.94% 1.94% 1.93%

Mid-term
adjusted AFR 1.99% 1.98% 1.98% 1.97%

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

REV. RUL. 2019-04 TABLE 3

Rates Under Section 382 for February 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.) 2.51%

REV. RUL. 2019-04 TABLE 4

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Appropriate Percentages Under Section 42(b)(1) for February 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 7.64%

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

REV. RUL. 2019-04 TABLE 5

Rate Under Section 7520 for February 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%