IRS Tax Law » Revenue Ruling 2003-93

Rev. Rul. 2003-93
Rev. Rul. 2003-93, 2003-33 I.R.B. 346, 2003-2 C.B. 346
                       Internal Revenue Service (I.R.S.)
                                 Revenue Ruling
     LOW-INCOME HOUSING CREDIT; SATISFACTORY BOND; “BOND FACTOR” AMOUNTS FOR
                     THE PERIOD JULY THROUGH SEPTEMBER 2003
                           Published: August 18, 2003

Low-income housing credit; satisfactory bond; “bond factor” amounts for the period July through September 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 July 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-in-come buildings or interests therein during the period July through September 2003.

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Table 1 Rev. Rul. 2003-93 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
————————————————-
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
————————————————-
Service or, if Section 42(f)(1) Election Was Made, the Succeeding
           Calendar Year
———————————————————————
1994   1995   1996   1997   1998   1999   2000   2001   2002   2003
———————————————————————
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
———————————————————————

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, 2002-44 I.R.B. 759. For dispositions occurring during the period January through March 2003, see Rev. Rul. 2003-22, 2003-8 I.R.B. 494. For dispositions occurring during the period April through June 2003, see Rev. Rul. 2003-44, 2003-18 I.R.B. 848.

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. 2003-93, 2003-33 I.R.B. 346, 2003-2 C.B. 346

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