Internal Revenue Bulletin — Rulings & Guidance
Rev. Rul. 2019-25 — Federal rates; adjusted federal rates; adjusted federal long-term rate, the long-term exempt rate, and the blended annual rate.
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 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 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% |
Section 42.—Low-Income Housing Credit
The applicable federal short-term, mid-term, and long-term rates are set forth for the month of November 2019. See Rev. Rul. 2019-25, page 1042.
Section 280G.—Golden Parachute Payments
The applicable federal short-term, mid-term, and long-term rates are set forth for the month of November 2019. See Rev. Rul. 2019-25, page 1042.
Section 382.—Limitation on Net Operating Loss Carryforwards and Certain Built-In Losses Following Ownership Change
The adjusted applicable federal long-term rate is set forth for the month of November 2019. See Rev. Rul. 2019-25, page 1042.
Section 467.—Certain Payments for the Use of Property or Services
The applicable federal short-term, mid-term, and long-term rates are set forth for the month of November 2019. See Rev. Rul. 2019-25, page 1042.
Section 468.—Special Rules for Mining and Solid Waste Reclamation and Closing Costs
The applicable federal short-term, mid-term, and long-term rates are set forth for the month of November 2019. See Rev. Rul. 2019-25, page 1042.
Section 482.—Allocation of Income and Deductions Among Taxpayers
The applicable federal short-term, mid-term, and long-term rates are set forth for the month of November 2019. See Rev. Rul. 2019-25, page 1042.
Section 483.—Interest on Certain Deferred Payments
The applicable federal short-term, mid-term, and long-term rates are set forth for the month of November 2019. See Rev. Rul. 2019-25, page 1042.
Section 1288.—Treatment of Original Issue Discount on Tax-Exempt Obligations
The adjusted applicable federal short-term, mid-term, and long-term rates are set forth for the month of November 2019. See Rev. Rul. 2019-25, page 1042.
Section 7520.—Valuation Tables
The applicable federal short-term, mid-term, and long-term rates are set forth for the month of November 2019. See Rev. Rul. 2019-25, page 1042.
Section 7872.—Treatment of Loans With Below-Market Interest Rates
The applicable federal short-term, mid-term, and long-term rates are set forth for the month of November 2019. See Rev. Rul. 2019-25, page 1042.
26 CFR 1.165-11
Source: official text