rr-14-01.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, 412, 467, 468, 482, 483, 642, 807, 846, 1288, 7520,
7872.)

# Rev. Rul. 2014-1

This revenue ruling provides various prescribed rates for federal
income tax purposes for January 2014 (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, with respect to housing credit dollar amount
allocations made before January 1, 2014, 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. Finally, Table 6
contains the deemed rate of return for transfers made during calendar
year 2014 to pooled income funds described in ' 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.

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# REV. RUL. 2014-1 TABLE 1 Applicable Federal Rates (AFR) for January 2014

Period for Compounding

Annual

Semiannual

Quarterly

Monthly

Short-term

AFR

.25%

.25%

.25%

.25%

110% AFR

.28%

.28%

.28%

.28%

120% AFR

.30%

.30%

.30%

.30%

130% AFR

.33%

.33%

.33%

.33%

Mid-term

AFR

1.75%

1.74%

1.74%

1.73%

110% AFR

1.92%

1.91%

1.91%

1.90%

120% AFR

2.10%

2.09%

2.08%

2.08%

130% AFR

2.27%

2.26%

2.25%

2.25%

150% AFR

2.63%

2.61%

2.60%

2.60%

175% AFR

3.07%

3.05%

3.04%

3.03%

Long-term

AFR

3.49%

3.46%

3.45%

3.44%

110% AFR

3.85%

3.81%

3.79%

3.78%

120% AFR

4.19%

4.15%

4.13%

4.11%

130% AFR

4.55%

4.50%

4.47%

4.46%

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REV. RUL. 2014-1 TABLE 2 Adjusted AFR for January 2014

Period for Compounding

Annual

Semiannual

Quarterly

Monthly

Short-term adjusted AFR

.25%

.25%

25%

.25%

Mid-term adjusted AFR

1.56%

1.55%

1.55%

1.55%

Long-term adjusted AFR

3.49%

3.46%

3.45%

3.44%

REV. RUL. 2014-1 TABLE 3
Rates Under Section 382 for January 2014

Adjusted federal long-term rate for the current month
3.49%

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.)

3.49%

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## REV. RUL. 2014-1 TABLE 4

Appropriate Percentages Under Section 42(b)(1) for January 2014
Note: Under section 42(b)(2), the applicable percentage for non-federally subsidized
new buildings placed in service after July 30, 2008, with respect to housing credit dollar
amount allocations made before January 1, 2014, shall not be less than 9%.

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

7.60%

Appropriate percentage for the 30% present value low-income

housing credit

3.26%

## REV. RUL. 2014-1 TABLE 5 Rate Under Section 7520 for January 2014

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%

## REV. RUL. 2014-1 TABLE 6

### Deemed Rate for Transfers to New Pooled Income Funds During 2014

Deemed rate of return for transfers during 2014 to pooled income funds
that have been in existence for less than 3 taxable years
1.4%