rr-19-20.pdf

us-irs-revenue-rulings-rr-19-20rr-19-20.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. 2019-20

This revenue ruling provides various prescribed rates for federal
income tax purposes for September 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.

REV. RUL. 2019-20 TABLE 1

2
Applicable Federal Rates (AFR) for September 2019

Period for Compounding
Annual Semiannual Quarterly Monthly

Short-term

AFR 1.85% 1.84% 1.84% 1.83%
110% AFR 2.03% 2.02% 2.01% 2.01%
120% AFR 2.22% 2.21% 2.20% 2.20%
130% AFR 2.40% 2.39% 2.38% 2.38%

Mid-term

AFR 1.78% 1.77% 1.77% 1.76%
110% AFR 1.96% 1.95% 1.95% 1.94%
120% AFR 2.13% 2.12% 2.11% 2.11%
130% AFR 2.31% 2.30% 2.29% 2.29%
150% AFR 2.68% 2.66% 2.65% 2.65%
175% AFR 3.12% 3.10% 3.09% 3.08%

Long-term

AFR 2.21% 2.20% 2.19% 2.19%
110% AFR 2.43% 2.42% 2.41% 2.41%
120% AFR 2.66% 2.64% 2.63% 2.63%
130% AFR 2.88% 2.86% 2.85% 2.84%

REV. RUL. 2019-20 TABLE 2

Adjusted AFR for September 2019

3

Period for Compounding
Annual Semiannual Quarterly Monthly
Short-term
adjusted AFR 1.40% 1.40% 1.40% 1.40%

Mid-term
adjusted AFR 1.34% 1.34% 1.34% 1.34%

Long-term
adjusted AFR 1.68% 1.67% 1.67% 1.66%

REV. RUL. 2019-20 TABLE 3

Rates Under Section 382 for September 2019

Adjusted federal long-term rate for the current month 1.68%

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.) 1.89%

REV. RUL. 2019-20 TABLE 4

Appropriate Percentages Under Section 42(b)(1) for September 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 7.46%

Appropriate percentage for the 30% present value low-income
housing credit 3.20%

REV. RUL. 2019-20 TABLE 5

Rate Under Section 7520 for September 2019

4
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 2.2%

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