rr-07-44.pdf

us-irs-revenue-rulings-rr-07-44rr-07-44.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, 412, 467, 468, 482, 483, 642, 807, 846, 1288, 7520,
7872.)

## Rev. Rul. 2007-44

This revenue ruling provides various prescribed rates for federal income tax
purposes for July 2007 (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)(2) for buildings placed in service during the current month.
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. Finally, Table 6 contains the blended annual rate for 2007
for purposes of section 7872.

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# REV. RUL. 2007-44 TABLE 1 Applicable Federal Rates (AFR) for July 2007

Period for Compounding

Annual

Semiannual

Quarterly

Monthly

Short-term

AFR

4.97%

4.91%

4.88%

4.86%

110% AFR

5.47%

5.40%

5.36%

5.34%

120% AFR

5.98%

5.89%

5.85%

5.82%

130% AFR

6.48%

6.38%

6.33%

6.30%

Mid-term

AFR

4.95%

4.89%

4.86%

4.84%

110% AFR

5.45%

5.38%

5.34%

5.32%

120% AFR

5.96%

5.87%

5.83%

5.80%

130% AFR

6.46%

6.36%

6.31%

6.28%

150% AFR

7.47%

7.34%

7.27%

7.23%

175% AFR

8.74%

8.56%

8.47%

8.41%

Long-term

AFR

5.15%

5.09%

5.06%

5.04%

110% AFR

5.68%

5.60%

5.56%

5.54%

120% AFR

6.20%

6.11%

6.06%

6.03%

130% AFR

6.73%

6.62%

6.57%

6.53%

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REV. RUL. 2007-44 TABLE 2 Adjusted AFR for July 2007

Period for Compounding Annual Semiannual Quarterly Monthly

Short-term adjusted AFR

3.66%

3.63%

3.61%

3.60%

Mid-term adjusted AFR

3.81%

3.77%

3.75%

3.74%

Long-term adjusted AFR

4.32%

4.27%

4.25%

4.23%

REV. RUL. 2007-44 TABLE 3
Rates Under Section 382 for July 2007

Adjusted federal long-term rate for the current month
4.32%

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.)
4.32%

REV. RUL. 2007-44 TABLE 4

Appropriate Percentages Under Section 42(b)(2) for July 2007

Appropriate percentage for the 70% present value low-income

housing credit

8.18%

Appropriate percentage for the 30% present value low-income

housing credit

3.50%

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# REV. RUL. 2007-44 TABLE 5 Rate Under Section 7520 for July 2007

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
6.0%

REV. RUL. 2007-44 TABLE 6
Blended Annual Rate for 2007

Section 7872(e)(2) blended annual rate for 2007
4.92%

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