IRS Tax Law » Revenue Ruling 2003-117

Rev. Rul. 2003-117
Rev. Rul. 2003-117, 2003-46 I.R.B. 1051, 2003-2 C.B. 1051
                       Internal Revenue Service (I.R.S.)
                                 Revenue Ruling
     LOW-INCOME HOUSING CREDIT; SATISFACTORY BOND; “BOND FACTOR” AMOUNTS FOR
                    THE PERIOD OCTOBER THROUGH DECEMBER 2003
                          Published: November 17, 2003

Section 42.–Low-Income Housing Credit

Low-income housing credit; satisfactory bond; “bond factor” amounts for the period October through December 2003. This ruling announces the monthly bond factor amounts to be used by taxpayers who dispose of qualified low-income buildings or interests therein during the period October through December 2003. This ruling also provides a summary of the bond factor amounts for dispositions occurring during the period January through September 2003.

In Rev. Rul. 90-60, 1990-2 C.B. 3, the Internal Revenue Service provided guidance to taxpayers concerning the general methodology used by the Treasury Department in computing the bond factor amounts used in calculating the amount of bond considered satisfactory by the Secretary under s 42(j)(6) of the Internal Revenue Code. It further announced that the Secretary would publish in the Internal Revenue Bulletin a table of bond factor amounts for dispositions occurring during each calendar month.

Rev. Proc. 99-11, 1999-1 C.B. 275, established a collateral program as an alternative to providing a surety bond for taxpayers to avoid or defer recapture of the low-income housing tax credits under s 42(j)(6). Under this program, taxpayers may establish a Treasury Direct Account and pledge certain United States Treasury securities to the Internal Revenue Service as security.

This revenue ruling provides in Table 1 the bond factor amounts for calculating the amount of bond considered satisfactory under s 42(j)(6) or the amount of United States Treasury securities to pledge in a Treasury Direct Account under Rev. Proc. 99-11 for dispositions of qualified low-income buildings or interests therein during the period October through December 2003. Table 1 also provides a summary of the bond factor amounts for dispositions occurring during the period January through September 2003.

[Note: The following TABLE/FORM is too wide to be displayed on one screen.

You must print it for a meaningful review of its contents. The table has been

divided into multiple pieces with each piece containing information to help you

assemble a printout of the table. The information for each piece includes: (1)

a three line message preceding the tabular data showing by line # and

character # the position of the upper left-hand corner of the piece and the

position of the piece within the entire table; and (2) a numeric scale

following the tabular data displaying the character positions.]

——————————————————————————-
                                                       Table 1
      Rev. Rul. 2003-117 Monthly Bond Factor Amounts for Dispositions Expressed
——————————————————————————-
—————————————
As a Percentage of Total Credits
—————————————
                 Calendar Year Building Placed in
————————————————-
Month of     1989   1990   1991   1992   1993
Disposition
————————————————-
      Jan ‘03 16.23 30.04 41.83 51.93 60.50
      Feb ‘03 16.23 30.04 41.83 51.93 60.50
      Mar ‘03 16.23 30.04 41.83 51.93 60.50
      Apr ‘03 16.23 30.04 41.83 51.93 60.50
      May ‘03 16.23 30.04 41.83 51.93 60.50
      Jun ‘03 16.23 30.04 41.83 51.93 60.50
      Jul ‘03 16.23 30.04 41.83 51.93 60.50
      Aug ‘03 16.23 30.04 41.83 51.93 60.50
      Sep ‘03 16.23 30.04 41.83 51.93 60.50
      Oct ‘03 15.43 28.55 39.76 49.36 57.50
      Nov ‘03 15.43 28.55 39.76 49.36 57.50
      Dec ‘03 15.43 28.55 39.76 49.36 57.50
————————————————-
Service or, if Section 42(f)(1) Election Was Made, the Succeeding
           Calendar Year
———————————————————————
1994   1995   1996   1997   1998   1999   2000   2001   2002   2003
———————————————————————
60.24 60.12 60.11 60.18 60.39 60.62 60.89 61.55 62.49 62.68
60.09 59.97 59.96 60.03 60.24 60.47 60.75 61.41 62.33 62.68
59.94 59.82 59.82 59.89 60.10 60.33 60.62 61.27 62.19 62.68
59.79 59.68 59.68 59.75 59.96 60.20 60.49 61.15 62.06 62.68
59.65 59.54 59.54 59.61 59.83 60.07 60.37 61.04 61.96 62.68
59.51 59.40 59.40 59.48 59.70 59.95 60.26 60.93 61.86 62.68
59.37 59.27 59.27 59.35 59.58 59.83 60.15 60.83 61.77 62.68
59.24 59.14 59.14 59.23 59.45 59.72 60.05 60.74 61.70 62.68
59.11 59.01 59.02 59.10 59.34 59.60 59.95 60.65 61.63 62.68
55.51 54.87 54.34 53.89 53.57 53.29 53.09 53.21 53.58 54.15
55.39 54.76 54.23 53.78 53.47 53.20 53.01 53.15 53.54 54.15
55.28 54.64 54.12 53.68 53.38 53.12 52.94 53.09 53.50 54.15
———————————————————————

For a list of bond factor amounts applicable to dispositions occurring during other calendar years, see: Rev. Rul. 98-3, 1998-1 C.B. 248; Rev. Rul. 2001-2, 2001-1 C.B. 255; Rev. Rul. 2001-53, 2001-2 C.B. 488; and Rev. Rul. 2002-72, 2002-2 C.B. 759.

DRAFTING INFORMATION

The principal author of this revenue ruling is Gregory N. Doran of the Office of Associate Chief Counsel (Passthroughs and Special Industries). For further information regarding this revenue ruling, contact Mr. Doran at (202) 622-3040 (not a toll-free call).

Rev. Rul. 2003-117, 2003-46 I.R.B. 1051, 2003-2 C.B. 1051

Bookmark to: