rr-19-23.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. 2019-23

This revenue ruling provides various prescribed rates for federal
income tax purposes for October 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. 2019-23 TABLE 1

2
Applicable Federal Rates (AFR) for October 2019

Period for Compounding
Annual Semiannual Quarterly Monthly

Short-term

AFR 1.69% 1.68% 1.68% 1.67%
110% AFR 1.86% 1.85% 1.85% 1.84%
120% AFR 2.03% 2.02% 2.01% 2.01%
130% AFR 2.19% 2.18% 2.17% 2.17%

Mid-term

AFR 1.51% 1.50% 1.50% 1.50%
110% AFR 1.66% 1.65% 1.65% 1.64%
120% AFR 1.81% 1.80% 1.80% 1.79%
130% AFR 1.96% 1.95% 1.95% 1.94%
150% AFR 2.26% 2.25% 2.24% 2.24%
175% AFR 2.65% 2.63% 2.62% 2.62%

Long-term

AFR 1.86% 1.85% 1.85% 1.84%
110% AFR 2.05% 2.04% 2.03% 2.03%
120% AFR 2.23% 2.22% 2.21% 2.21%
130% AFR 2.42% 2.41% 2.40% 2.40%

REV. RUL. 2019-23 TABLE 2

Adjusted AFR for October 2019

3

Period for Compounding
Annual Semiannual Quarterly Monthly
Short-term
adjusted AFR 1.28% 1.28% 1.28% 1.28%

Mid-term
adjusted AFR 1.14% 1.14% 1.14% 1.14%

Long-term
adjusted AFR 1.40% 1.40% 1.40% 1.40%

REV. RUL. 2019-23 TABLE 3

Rates Under Section 382 for October 2019

Adjusted federal long-term rate for the current month 1.40%

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.) 1.77%

REV. RUL. 2019-23 TABLE 4

Appropriate Percentages Under Section 42(b)(1) for October 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 7.39%

Appropriate percentage for the 30% present value low-income
housing credit 3.17%

REV. RUL. 2019-23 TABLE 5

Rate Under Section 7520 for October 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 1.8%