Internal Revenue Bulletin 2019-10 (PDF rendition): IRS Revenue Rulings

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HIGHLIGHTS
OF THIS ISSUE
These synopses are intended only as aids to the reader in
identifying the subject matter covered. They may not be
relied upon as authoritative interpretations.
EMPLOYEE PLANS
Notice 2019–16, page 763.
This notice sets forth updates on thecorporate bond monthly
yield curve, the corresponding spot segment rates for February
2019 used under § 417(e)(3)(D), the 24-month average segment
rates applicable for February 2019, and the 30-year Treasury
rates, as reflected by the application of § 430(h)(2)(C)(iv).
INCOME TAX
REV. RUL. 2019–07, page 761.
Federal rates; adjusted federal rates; adjusted federal long-
term rate, the long-term exempt rate, and the blended annual
rate. For purposes of sections 382, 1274, 1288, 7872 and
other sections of the Code, tables set forth the rates for March
2019.
Finding Lists begin on page ii.
Bulletin No. 2019–10
March 04, 2019

The IRS Mission
Provide America’s taxpayers top-quality service by helping
them understand and meet their tax responsibilities and en-
force the law with integrity and fairness to all.
Introduction
The Internal Revenue Bulletin is the authoritative instrument of
the Commissioner of Internal Revenue for announcing official
rulings and procedures of the Internal Revenue Service and for
publishing Treasury Decisions, Executive Orders, Tax Conven-
tions, legislation, court decisions, and other items of general
interest. It is published weekly.
It is the policy of the Service to publish in the Bulletin all
substantive rulings necessary to promote a uniform application
of the tax laws, including all rulings that supersede, revoke,
modify, or amend any of those previously published in the
Bulletin. All published rulings apply retroactively unless other-
wise indicated. Procedures relating solely to matters of internal
management are not published; however, statements of inter-
nal practices and procedures that affect the rights and duties
of taxpayers are published.
Revenue rulings represent the conclusions of the Service on
the application of the law to the pivotal facts stated in the
revenue ruling. In those based on positions taken in rulings to
taxpayers or technical advice to Service field offices, identify-
ing details and information of a confidential nature are deleted
to prevent unwarranted invasions of privacy and to comply with
statutory requirements.
Rulings and procedures reported in the Bulletin do not have the
force and effect of Treasury Department Regulations, but they
may be used as precedents. Unpublished rulings will not be
relied on, used, or cited as precedents by Service personnel in
the disposition of other cases. In applying published rulings and
procedures, the effect of subsequent legislation, regulations,
court decisions, rulings, and procedures must be considered,
and Service personnel and others concerned are cautioned
against reaching the same conclusions in other cases unless
the facts and circumstances are substantially the same.
The Bulletin is divided into four parts as follows:
Part I.—1986 Code.
This part includes rulings and decisions based on provisions of
the Internal Revenue Code of 1986.
Part II.—Treaties and Tax Legislation.
This part is divided into two subparts as follows: Subpart A, Tax
Conventions and Other Related Items, and Subpart B, Legisla-
tion and Related Committee Reports.
Part III.—Administrative, Procedural, and Miscellaneous.
To the extent practicable, pertinent cross references to these
subjects are contained in the other Parts and Subparts. Also
included in this part are Bank Secrecy Act Administrative Rul-
ings. Bank Secrecy Act Administrative Rulings are issued by
the Department of the Treasury’s Office of the Assistant Sec-
retary (Enforcement).
Part IV.—Items of General Interest.
This part includes notices of proposed rulemakings, disbar-
ment and suspension lists, and announcements.
The last Bulletin for each month includes a cumulative index for
the matters published during the preceding months. These
monthly indexes are cumulated on a semiannual basis, and are
published in the last Bulletin of each semiannual period.
The contents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate.
March 04, 2019Bulletin No. 2019–10

Part I. Rulings and Decisions Under the Internal Revenue Code
of 1986
Section 1274.--Determina-
tion 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. 2019–07
This revenue ruling provides various
prescribed rates for federal income tax
purposes for March 2019 (the current
month). Table 1 contains the short-term,
mid-term, and long-term applicable fed-
eral 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 sec-
tion 1288(b). Table 3 sets forth the ad-
justed 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 sec-
tion 42(b)(1) for buildings placed in ser-
vice during the current month. However,
under section 42(b)(2), the applicable per-
centage 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 de-
termining 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. 2019–07 TABLE 1
Applicable Federal Rates (AFR) for March 2019
Period for Compounding
AnnualSemiannualQuarterlyMonthly
Short-term
AFR2.55%2.53%2.52%2.52%
110% AFR2.80%2.78%2.77%2.76%
120% AFR3.06%3.04%3.03%3.02%
130% AFR3.32%3.29%3.28%3.27%
Mid-term
AFR2.59%2.57%2.56%2.56%
110% AFR2.85%2.83%2.82%2.81%
120% AFR3.10%3.08%3.07%3.06%
130% AFR3.37%3.34%3.33%3.32%
150% AFR3.90%3.86%3.84%3.83%
175% AFR4.55%4.50%4.47%4.46%
Long-term
AFR2.91%2.89%2.88%2.87%
110% AFR3.21%3.18%3.17%3.16%
120% AFR3.50%3.47%3.46%3.45%
130% AFR3.80%3.76%3.74%3.73%
REV. RUL. 2019–07 TABLE 2
Adjusted AFR for March 2019
Period for Compounding
AnnualSemiannualQuarterlyMonthly
Short-term adjusted AFR1.93%1.92%1.92%1.91%
Mid-term adjusted AFR1.96%1.95%1.95%1.94%
Long-term adjusted AFR2.20%2.19%2.18%2.18%
Bulletin No. 2019–10March 04, 2019
761

REV. RUL. 2019–07 TABLE 3
Rates Under Section 382 for March 2019
Adjusted federal long-term rate for the current month2.20%
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.)
2.39%
REV. RUL. 2019–07 TABLE 4
Appropriate Percentages Under Section 42(b)(1) for March 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 credit7.63%
Appropriate percentage for the 30% present value low-income housing credit3.27%
REV. RUL. 2019–07 TABLE 5
Rate Under Section 7520 for March 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
3.2%
March 04, 2019Bulletin No. 2019–10
762

Part III. Administrative, Procedural, and Miscellaneous
Update for Weighted
Average Interest Rates,
Yield Curves, and Segment
Rates
Notice 2019–16
This notice provides guidance on the
corporate bond monthly yield curve, the
corresponding spot segment rates used un-
der § 417(e)(3), and the 24-month average
segment rates under § 430(h)(2) of the
Internal Revenue Code. In addition, this
notice provides guidance as to the interest
rate on 30-year Treasury securities under
§ 417(e)(3)(A)(ii)(II) as in effect for plan
years beginning before 2008 and the 30-
year Treasury weighted average rate un-
der § 431(c)(6)(E)(ii)(I).
YIELD CURVE AND SEGMENT
RATES
Section 430 specifies the minimum
funding requirements that apply to single-
employer plans (except for CSEC plans
under § 414(y)) pursuant to § 412. Section
430(h)(2) specifies the interest rates that
must be used to determine a plan’s target
normal cost and funding target. Under this
provision, present value is generally de-
termined using three 24-month average
interest rates (“segment rates”), each of
which applies to cash flows during speci-
fied periods. To the extent provided under
§ 430(h)(2)(C)(iv),these segment rates are
adjusted by the applicable percentage of the
25-year average segment rates for the period
ending September 30 of the year preceding
the calendar year in which the plan year
begins.
1
However, an election may be made
under § 430(h)(2)(D)(ii) to use the monthly
yield curve in place of the segment rates.
Notice 2007– 81, 2007– 44 I.R.B. 899,
provides guidelines for determining the
monthly corporate bond yield curve, and
the 24-month average corporate bond seg-
ment rates used to compute the target nor-
mal cost and the funding target. Consis-
tent with the methodology specified in
Notice 2007– 81, the monthly corporate
bond yield curve derived from January
2019 data is in Table 2019 –1 at the end of
this notice. The spot first, second, and
third segment rates for the month of Jan-
uary 2019 are, respectively, 3.19, 4.25,
and 4.60.
The 24-month average segment rates de-
termined under § 430(h)(2)(C)(i) through
(iii) must be adjusted pursuant to § 430(h)
(2)(C)(iv) to be within the applicable mini-
mum and maximum percentages of the cor-
responding 25-year average segment rates.
For plan years beginning before 2021, the
applicable minimum percentage is 90% and
the applicable maximum percentage is
110%. The 25-year average segment rates
for plan years beginning in 2018 and 2019
werepublishedinNotice2017–50,
2017– 41 I.R.B. 280, and Notice 2018 –73,
2018 – 40 I.R.B. 526, respectively.
24-MONTH AVERAGE CORPORATE
BOND SEGMENT RATES
The three 24-month average corporate
bond segment rates applicable for Febru-
ary 2019 without adjustment for the 25-
year average segment rate limits are as
follows:
24-Month Average Segment Rates Without 25-Year Average Adjustment
Applicable MonthFirst SegmentSecond SegmentThird Segment
February 20192.603.944.49
Based on § 430(h)(2)(C)(iv), the 24-
month averages applicable for September
2018, adjusted to be within the applicable
minimum and maximum percentages of
the corresponding 25-
Based on § 430(h)(2)(C)(iv), the 24-
month averages applicable for February
2019, adjusted to be within the applicable
minimum and maximum percentages of
the corresponding 25-year average seg-
ment rates, are as follows:
Adjusted 24-Month Average Segment Rates
For Plan Years
Beginning InApplicable MonthFirst SegmentSecond SegmentThird Segment
2018February 20193.925.526.29
2019February 20193.745.356.11
30-YEAR TREASURY SECURITIES
INTEREST RATES
Section 431specifies the minimum
funding requirements that apply to multiem-
ployer plans pursuant to § 412. Section
431(c)(6)(B) specifies a minimum amount
for the full-funding limitation described in
§ 431(c)(6)(A), based on the plan’s current
liability. Section 431(c)(6)(E)(ii)(I) provides
that the interest rate used to calculate current
liability for this purpose must be no more
than 5 percent above and no more than 10
percent below the weighted average of the
rates of interest on 30-year Treasury securi-
ties during the four-year period ending on
the last day before the beginning of the plan
year. Notice 88 –73, 1988 –2 C.B. 383, pro-
videsguidelinesfordeterminingthe
weighted average interest rate. The rate of
interest on 30-year Treasury securities for
January 2019 is 3.04 percent. The Service
determined this rate as the average of the
daily determinations of yield on the 30-year
1
Pursuant to § 433(h)(3)(A), the 3
rd
segment rate determined under § 430(h)(2)(C) is used to determine the current liability of a CSEC plan (which is used to calculate the minimum amount
of the full funding limitation under § 433(c)(7)(C)).
Bulletin No. 2019–10March 04, 2019
763

Treasury bond maturing in November 2048.
For plan years beginning in February 2019,
the weighted average of the rates of interest
on 30-year Treasury securities and the per-
missible range of rates used to calculate
current liability are as follows:
Treasury Weighted Average Rates
For Plan Years
Beginning In
30-Year Treasury
Weighted Average
Permissible Range
90% to 105%
Feburary 20192.922.63 to 3.07
MINIMUM PRESENT VALUE
SEGMENT RATES
In general, the applicable interest rates
under § 417(e)(3)(D) are segment rates
computed without regard to a 24-month
average. Notice 2007– 81 provides guide-
lines for determining the minimum pres-
ent value segment rates. Pursuant to that
notice, the minimum present value seg-
ment rates determined for January 2019
are as follows:
Minimum Present Value Segment Rates
MonthFirst SegmentSecond SegmentThird Segment
January 20193.194.254.60
DRAFTING INFORMATION
The principal author of this notice is
Tom Morgan of the Office of the Associ-
ate Chief Counsel (Employee Benefits,
Exempt Organizations, and Employment
Taxes). However, other personnel from
the IRS participated in the development of
this guidance. For further information re-
garding this notice, contact Mr. Morgan at
202-317-6700 or Paul Stern at 202-317-
8702 (not toll-free numbers).
March 04, 2019Bulletin No. 2019–10
764

Table 2019–1
Monthly Yield Curve for January 2019
Derived from January 2019 Data
MaturityYieldMaturityYieldMaturityYieldMaturityYieldMaturityYield
0.52.8420.54.5740.54.6060.54.6280.54.63
1.02.9721.04.5741.04.6161.04.6281.04.63
1.53.0821.54.5741.54.6161.54.6281.54.63
2.03.1622.04.5742.04.6162.04.6382.04.63
2.53.2122.54.5742.54.6162.54.6382.54.63
3.03.2523.04.5743.04.6163.04.6383.04.63
3.53.2823.54.5743.54.6163.54.6383.54.63
4.03.3224.04.5744.04.6164.04.6384.04.64
4.53.3724.54.5744.54.6164.54.6384.54.64
5.03.4225.04.5745.04.6165.04.6385.04.64
5.53.4925.54.5745.54.6165.54.6385.54.64
6.03.5626.04.5746.04.6166.04.6386.04.64
6.53.6326.54.5846.54.6166.54.6386.54.64
7.03.7127.04.5847.04.6167.04.6387.04.64
7.53.7927.54.5847.54.6167.54.6387.54.64
8.03.8728.04.5848.04.6168.04.6388.04.64
8.53.9528.54.5848.54.6168.54.6388.54.64
9.04.0229.04.5849.04.6169.04.6389.04.64
9.54.0929.54.5849.54.6269.54.6389.54.64
10.04.1530.04.5850.04.6270.04.6390.04.64
10.54.2130.54.5950.54.6270.54.6390.54.64
11.04.2631.04.5951.04.6271.04.6391.04.64
11.54.3131.54.5951.54.6271.54.6391.54.64
12.04.3532.04.5952.04.6272.04.6392.04.64
12.54.3932.54.5952.54.6272.54.6392.54.64
13.04.4233.04.5953.04.6273.04.6393.04.64
13.54.4533.54.5953.54.6273.54.6393.54.64
14.04.4734.04.5954.04.6274.04.6394.04.64
14.54.4934.54.5954.54.6274.54.6394.54.64
15.04.5135.04.6055.04.6275.04.6395.04.64
15.54.5235.54.6055.54.6275.54.6395.54.64
16.04.5336.04.6056.04.6276.04.6396.04.64
16.54.5436.54.6056.54.6276.54.6396.54.64
17.04.5537.04.6057.04.6277.04.6397.04.64
17.54.5537.54.6057.54.6277.54.6397.54.64
18.04.5638.04.6058.04.6278.04.6398.04.64
18.54.5638.54.6058.54.6278.54.6398.54.64
19.04.5639.04.6059.04.6279.04.6399.04.64
19.54.5639.54.6059.54.6279.54.6399.54.64
20.04.5740.04.6060.04.6280.04.63100.04.64
Bulletin No. 2019–10March 04, 2019
765

Definition of Terms
Revenue rulings and revenue procedures
(hereinafter referred to as “rulings”) that
have an effect on previous rulings use the
following defined terms to describe the
effect:
Amplifieddescribes a situation where
no change is being made in a prior pub-
lished position, but the prior position is
being extended to apply to a variation of
the fact situation set forth therein. Thus, if
an earlier ruling held that a principle ap-
plied to A, and the new ruling holds that
the same principle also applies to B, the
earlier ruling is amplified. (Compare with
modified, below).
Clarifiedis used in those instances
where the language in a prior ruling is
being made clear because the language
has caused, or may cause, some confu-
sion. It is not used where a position in a
prior ruling is being changed.
Distinguisheddescribes a situation
where a ruling mentions a previously pub-
lished ruling and points out an essential
difference between them.
Modifiedis used where the substance
of a previously published position is being
changed. Thus, if a prior ruling held that a
principle applied to A but not to B, and the
new ruling holds that it applies to both A
and B, the prior ruling is modified because
it corrects a published position. (Compare
withamplifiedandclarified, above).
Obsoleteddescribes a previously pub-
lished ruling that is not considered deter-
minative with respect to future transac-
tions. This term is most commonly used in
a ruling that lists previously published rul-
ings that are obsoleted because of changes
in laws or regulations. A ruling may also
be obsoleted because the substance has
been included in regulations subsequently
adopted.
Revokeddescribes situations where the
position in the previously published ruling
is not correct and the correct position is
being stated in a new ruling.
Supersededdescribes a situation where
the new ruling does nothing more than
restate the substance and situation of a
previously published ruling (or rulings).
Thus, the term is used to republish under
the 1986 Code and regulations the same
position published under the 1939 Code
and regulations. The term is also used
when it is desired to republish in a single
ruling a series of situations, names, etc.,
that were previously published over a pe-
riod of time in separate rulings. If the new
ruling does more than restate the sub-
stance of a prior ruling, a combination of
terms is used. For example,modifiedand
supersededdescribes a situation where the
substance of a previously published ruling
is being changed in part and is continued
without change in part and it is desired to
restate the valid portion of the previously
published ruling in a new ruling that is
self contained. In this case, the previously
published ruling is first modified and then,
as modified, is superseded.
Supplementedis used in situations in
which a list, such as a list of the names of
countries, is published in a ruling and that
list is expanded by adding further names
in subsequent rulings. After the original
ruling has been supplemented several
times, a new ruling may be published that
includes the list in the original ruling and
the additions, and supersedes all prior rul-
ings in the series.
Suspendedis used in rare situations to
show that the previous published rulings
will not be applied pending some future
action such as the issuance of new or
amended regulations, the outcome of
cases in litigation, or the outcome of a
Service study.
Abbreviations
The following abbreviations in current
use and formerly used will appear in ma-
terial published in the Bulletin.
A—Individual.
Acq.—Acquiescence.
B—Individual.
BE—Beneficiary.
BK—Bank.
B.T.A.—Board of Tax Appeals.
C—Individual.
C.B.—Cumulative Bulletin.
CFR—Code of Federal Regulations.
CI—City.
COOP—Cooperative.
Ct.D.—Court Decision.
CY—County.
D—Decedent.
DC—Dummy Corporation.
DE—Donee.
Del. Order—Delegation Order.
DISC—Domestic International Sales Corporation.
DR—Donor.
E—Estate.
EE—Employee.
E.O.—Executive Order.
ER—Employer.
ERISA—Employee Retirement Income Security Act.
EX—Executor.
F—Fiduciary.
FC—Foreign Country.
FICA—Federal Insurance Contributions Act.
FISC—Foreign International Sales Company.
FPH—Foreign Personal Holding Company.
F.R.—Federal Register.
FUTA—Federal Unemployment Tax Act.
FX—Foreign corporation.
G.C.M.—Chief Counsel’s Memorandum.
GE—Grantee.
GP—General Partner.
GR—Grantor.
IC—Insurance Company.
I.R.B.—Internal Revenue Bulletin.
LE—Lessee.
LP—Limited Partner.
LR—Lessor.
M—Minor.
Nonacq.—Nonacquiescence.
O—Organization.
P—Parent Corporation.
PHC—Personal Holding Company.
PO—Possession of the U.S.
PR—Partner.
PRS—Partnership.
PTE
—Prohibited Transaction Exemption.
Pub. L.—Public Law.
REIT—Real Estate Investment Trust.
Rev. Proc.—Revenue Procedure.
Rev. Rul.—Revenue Ruling.
S—Subsidiary.
S.P.R.—Statement of Procedural Rules.
Stat.—Statutes at Large.
T—Target Corporation.
T.C.—Tax Court.
T.D.—Treasury Decision.
TFE—Transferee.
TFR—Transferor.
T.I.R.—Technical Information Release.
TP—Taxpayer.
TR—Trust.
TT—Trustee.
U.S.C.—United States Code.
X—Corporation.
Y—Corporation.
Z—Corporation.
Bulletin No. 2019–10March 04, 2019
i

Numerical Finding List
1
Bulletin 2019 –10
Action on Decision:
2019-1, 2019-08 I.R.B.569
Announcements:
2019-1, 2019-06 I.R.B.566
Notices:
2019-01, 2019-02 I.R.B.275
2019-02, 2019-02 I.R.B.281
2019-03, 2019-03 I.R.B.350
2019-04, 2019-02 I.R.B.282
2019-05, 2019-02 I.R.B.283
2019-06, 2019-03 I.R.B.353
2019-07, 2019-09 I.R.B.740
2019-08, 2019-03 I.R.B.354
2019-09, 2019-04 I.R.B.403
2019-11, 2019-05 I.R.B.430
2019-13, 2019-08 I.R.B.580
2019-16, 2019-10 I.R.B.763
Proposed Regulations:
REG-104259-18, 2019-02 I.R.B.300
REG-104352-18, 2019-03 I.R.B.357
REG-106089-18, 2019-05 I.R.B.431
REG-134652-18, 2019-09 I.R.B.747
REG-141739-08, 2019-09 I.R.B.757
Revenue Procedures:
2019-1, 2019-01 I.R.B.1
2019-2, 2019-01 I.R.B.106
2019-3, 2019-01 I.R.B.130
2019-4, 2019-01 I.R.B.146
2019-5, 2019-01 I.R.B.230
2019-6, 2019-02 I.R.B.284
2019-7, 2019-01 I.R.B.268
2019-8, 2019-03 I.R.B.347
2019-9, 2019-02 I.R.B.293
2019-10, 2019-02 I.R.B.296
2019-11, 2019-09 I.R.B.742
2019-12, 2019-04 I.R.B.401
2019-13, 2019-09 I.R.B.744
2019-16, 2019-10 I.R.B.763
Revenue Rulings:
2019-03, 2019-02 I.R.B.272
2019-04, 2019-07 I.R.B.567
2019-07, 2019-10 I.R.B.761
Treasury Decisions:
9845, 2019-08 I.R.B.570
9846, 2019-09 I.R.B.583
9847, 2019-09 I.R.B.670
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2018 –27 through 2018 –52 is in Internal Revenue Bulletin
2018 –52, dated December 27, 2018.
March 04, 2019Bulletin No. 2019–10
ii

Finding List of Current Actions on
Previously Published Items
1
Bulletin 2019 –10
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2018 –27 through 2018 –52 is in Internal Revenue Bulletin
2018 –52, dated December 27, 2018.
Bulletin No. 2019–10March 04, 2019
iii

INTERNAL REVENUE BULLETIN
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