rr-05-54.pdf

us-irs-revenue-rulings-rr-05-54rr-05-54.pdfGuidance

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# Part I

# 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. 2005-54

This revenue ruling provides various prescribed rates for federal income tax
purposes for August 2005 (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)(2) for buildings placed in service during the current month.
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 blended annual rate for 2005
for purposes of section 7872.

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# REV. RUL. 2005-54 TABLE 1 Applicable Federal Rates (AFR) for August 2005

Period for Compounding

Annual

Semiannual

Quarterly

Monthly

Short-term

AFR

3.58%

3.55%

3.53%

3.52%

110% AFR

3.95%

3.91%

3.89%

3.88%

120% AFR

4.31%

4.26%

4.24%

4.22%

130% AFR

4.67%

4.62%

4.59%

4.58%

Mid-term

AFR

3.92%

3.88%

3.86%

3.85%

110% AFR

4.32%

4.27%

4.25%

4.23%

120% AFR

4.71%

4.66%

4.63%

4.62%

130% AFR

5.10%

5.04%

5.01%

4.99%

150% AFR

5.90%

5.82%

5.78%

5.75%

175% AFR

6.91%

6.79%

6.73%

6.70%

Long-term

AFR

4.33%

4.28%

4.26%

4.24%

110% AFR

4.77%

4.71%

4.68%

4.66%

120% AFR

5.21%

5.14%

5.11%

5.09%

130% AFR

5.64%

5.56%

5.52%

5.50%

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REV. RUL. 2005-54 TABLE 2 Adjusted AFR for August 2005

Period for Compounding Annual Semiannual Quarterly Monthly

Short-term adjusted AFR

2.71%

2.69%

2.68%

2.68%

Mid-term adjusted AFR

3.11%

3.09%

3.08%

3.07%

Long-term adjusted AFR

4.12%

4.08%

4.06%

4.05%

REV. RUL. 2005-54 TABLE 3
Rates Under Section 382 for August 2005

Adjusted federal long-term rate for the current month
4.12%

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.)
4.20%

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# REV. RUL. 2005-54 TABLE 4 Appropriate Percentages Under Section 42(b)(2) forAugust 2005

REV. RUL. 2005-54 TABLE 5 Rate Under Section 7520 for August 2005

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

7.96%

Appropriate percentage for the 30% present value low-income

housing credit

3.41%

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
4.8%

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