rr-09-10.pdf

us-irs-revenue-rulings-rr-09-10rr-09-10.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. 2009-10

This revenue ruling provides various prescribed rates for federal income tax
purposes for April 2009 (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, and before December 31, 2013,
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. 2009-10 TABLE 1 Applicable Federal Rates (AFR) for April 2009

Period for Compounding

Annual

Semiannual

Quarterly

Monthly

Short-term

AFR

.83%

.83%

.83%

.83%

110% AFR

.91%

.91%

.91%

91%

120% AFR

1.00%

1.00%

1.00%

1.00%

130% AFR

1.08%

1.08%

1.08%

1.08%

Mid-term

AFR

2.15%

2.14%

2.13%

2.13%

110% AFR

2.36%

2.35%

2.34%

2.34%

120% AFR

2.59%

2.57%

2.56%

2.56%

130% AFR

2.80%

2.78%

2.77%

2.76%

150% AFR

3.24%

3.21%

3.20%

3.19%

175% AFR

3.79%

3.75%

3.73%

3.72%

Long-term

AFR

3.67%

3.64%

3.62%

3.61%

110% AFR

4.04%

4.00%

3.98%

3.97%

120% AFR

4.42%

4.37%

4.35%

4.33%

130% AFR

4.79%

4.73%

4.70%

4.68%

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REV. RUL. 2009-10 TABLE 2 Adjusted AFR for April 2009

Period for Compounding Annual Semiannual Quarterly Monthly

Short-term adjusted AFR

.87%

.87%

.87%

.87%

Mid-term adjusted AFR

2.39%

2.38%

2.37%

2.37%

Long-term adjusted AFR

4.61%

4.56%

4.53%

4.52%

REV. RUL. 2009-10 TABLE 3
Rates Under Section 382 for April 2009

Adjusted federal long-term rate for the current month
4.61%

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.)

5.27%

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# REV. RUL. 2009-10 TABLE 4 Appropriate Percentages Under Section 42(b)(1) for April 2009

Note: Under Section 42(b)(2), the applicable percentage for non-federally
subsidized new buildings placed in service after July 30, 2008, and before
December 31, 2013, shall not be less than 9%.

Appropriate percentage for the 70% present value low-income
housing credit
7.67%

Appropriate percentage for the 30% present value low-income
housing credit
3.29%

# REV. RUL. 2009-10 TABLE 5 Rate Under Section 7520 for April 2009

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
2.6%

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