rr-19-17.pdf

us-irs-revenue-rulings-rr-19-17rr-19-17.pdfGuidance

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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. 2019-17

This revenue ruling provides various prescribed rates for federal
income tax purposes for August 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. 2019-17 TABLE 1

2
Applicable Federal Rates (AFR) for August 2019

Period for Compounding
Annual Semiannual Quarterly Monthly

Short-term

AFR 1.91% 1.90% 1.90% 1.89%
110% AFR 2.10% 2.09% 2.08% 2.08%
120% AFR 2.29% 2.28% 2.27% 2.27%
130% AFR 2.49% 2.47% 2.46% 2.46%

Mid-term

AFR 1.87% 1.86% 1.86% 1.85%
110% AFR 2.06% 2.05% 2.04% 2.04%
120% AFR 2.24% 2.23% 2.22% 2.22%
130% AFR 2.43% 2.42% 2.41% 2.41%
150% AFR 2.81% 2.79% 2.78% 2.77%
175% AFR 3.29% 3.26% 3.25% 3.24%

Long-term

AFR 2.33% 2.32% 2.31% 2.31%
110% AFR 2.57% 2.55% 2.54% 2.54%
120% AFR 2.80% 2.78% 2.77% 2.76%
130% AFR 3.04% 3.02% 3.01% 3.00%

REV. RUL. 2019-17 TABLE 2

Adjusted AFR for August 2019

3

Period for Compounding
Annual Semiannual Quarterly Monthly
Short-term
adjusted AFR 1.45% 1.44% 1.44% 1.44%

Mid-term
adjusted AFR 1.41% 1.41% 1.41% 1.41%

Long-term
adjusted AFR 1.77% 1.76% 1.76% 1.75%

REV. RUL. 2019-17 TABLE 3

Rates Under Section 382 for August 2019

Adjusted federal long-term rate for the current month 1.77%

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.) 2.09%

REV. RUL. 2019-17 TABLE 4

Appropriate Percentages Under Section 42(b)(1) for August 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 7.48%

Appropriate percentage for the 30% present value low-income
housing credit 3.21%

REV. RUL. 2019-17 TABLE 5

Rate Under Section 7520 for August 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 2.2%

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