rr-19-25.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. 2019-25

This revenue ruling provides various prescribed rates for federal
income tax purposes for November 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. 2019-25 TABLE 1

2
Applicable Federal Rates (AFR) for November 2019

Period for Compounding
Annual Semiannual Quarterly Monthly

Short-term

AFR 1.68% 1.67% 1.67% 1.66%
110% AFR 1.85% 1.84% 1.84% 1.83%
120% AFR 2.01% 2.00% 2.00% 1.99%
130% AFR 2.18% 2.17% 2.16% 2.16%

Mid-term

AFR 1.59% 1.58% 1.58% 1.57%
110% AFR 1.75% 1.74% 1.74% 1.73%
120% AFR 1.91% 1.90% 1.90% 1.89%
130% AFR 2.06% 2.05% 2.04% 2.04%
150% AFR 2.38% 2.37% 2.36% 2.36%
175% AFR 2.79% 2.77% 2.76% 2.75%

Long-term

AFR 1.94% 1.93% 1.93% 1.92%
110% AFR 2.13% 2.12% 2.11% 2.11%
120% AFR 2.33% 2.32% 2.31% 2.31%
130% AFR 2.53% 2.51% 2.50% 2.50%

REV. RUL. 2019-25 TABLE 2

Adjusted AFR for November 2019

3

Period for Compounding
Annual Semiannual Quarterly Monthly
Short-term
adjusted AFR 1.27% 1.27% 1.27% 1.27%

Mid-term
adjusted AFR 1.20% 1.20% 1.20% 1.20%

Long-term
adjusted AFR 1.48% 1.47% 1.47% 1.47%

REV. RUL. 2019-25 TABLE 3

Rates Under Section 382 for November 2019

Adjusted federal long-term rate for the current month 1.48%

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.) 1.68%

REV. RUL. 2019-25 TABLE 4

Appropriate Percentages Under Section 42(b)(1) for November 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 7.40%

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

REV. RUL. 2019-25 TABLE 5

Rate Under Section 7520 for November 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 2.0%