rr-19-12.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. 2019-12

This revenue ruling provides various prescribed rates for federal
income tax purposes for May 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. 2019-12 TABLE 1

Applicable Federal Rates (AFR) for May 2019

Period for Compounding
Annual Semiannual Quarterly Monthly

Short-term

AFR 2.39% 2.38% 2.37% 2.37%
110% AFR 2.64% 2.62% 2.61% 2.61%
120% AFR 2.88% 2.86% 2.85% 2.84%
130% AFR 3.11% 3.09% 3.08% 3.07%

Mid-term

AFR 2.37% 2.36% 2.35% 2.35%
110% AFR 2.62% 2.60% 2.59% 2.59%
120% AFR 2.85% 2.83% 2.82% 2.81%
130% AFR 3.09% 3.07% 3.06% 3.05%
150% AFR 3.57% 3.54% 3.52% 3.51%
175% AFR 4.17% 4.13% 4.11% 4.09%

Long-term

AFR 2.74% 2.72% 2.71% 2.70%
110% AFR 3.01% 2.99% 2.98% 2.97%
120% AFR 3.29% 3.26% 3.25% 3.24%
130% AFR 3.57% 3.54% 3.52% 3.51%

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REV. RUL. 2019-12 TABLE 2

Adjusted AFR for May 2019

Period for Compounding
Annual Semiannual Quarterly Monthly
Short-term
adjusted AFR 1.82% 1.81% 1.81% 1.80%

Mid-term
adjusted AFR 1.80% 1.79% 1.79% 1.78%

Long-term
adjusted AFR 2.08% 2.07% 2.06% 2.06%

REV. RUL. 2019-12 TABLE 3

Rates Under Section 382 for May 2019

Adjusted federal long-term rate for the current month 2.08%

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.) 2.20%

REV. RUL. 2019-12 TABLE 4

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Appropriate Percentages Under Section 42(b)(1) for May 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 7.59%

Appropriate percentage for the 30% present value low-income
housing credit 3.25%

REV. RUL. 2019-12 TABLE 5

Rate Under Section 7520 for May 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 2.8%