IRS Tax Law » Revenue Ruling 2004-106

Rev. Rul. 2004-106
Rev. Rul. 2004-106, 2004-49 I.R.B. 893
                       Internal Revenue Service (I.R.S.)
                                 Revenue Ruling
      FEDERAL RATES; ADJUSTED FEDERAL RATES; ADJUSTED FEDERAL LONG-TERM RATE
                          AND THE LONG-TERM EXEMPT RATE
                           Released: November 17, 2004
                           Published: December 6, 2004

Section 42.–Low-Income Housing Credit

The adjusted applicable federal short-term, mid-term, and long-term rates are set forth for the month of December 2004.

Section 280G.–Golden Parachute Payments

Federal short-term, mid-term, and long-term rates are set forth for the month of December 2004.

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 December 2004.

Section 412.–Minimum Funding Standards

The adjusted applicable federal short-term, mid-term, and long-term rates are set forth for the month of December 2004.

Section 467.–Certain Payments for the Use of Property or Services

The adjusted applicable federal short-term, mid-term, and long-term rates are set forth for the month of December 2004.

Section 468.–Special Rules for Mining and Solid Waste Reclamation and Closing Costs

The adjusted applicable federal short-term, mid-term, and long-term rates are set forth for the month of December 2004.

Section 482.–Allocation of Income and Deductions Among Taxpayers

Federal short-term, mid-term, and long-term rates are set forth for the month of December 2004.

Section 483.–Interest on Certain Deferred Payments

The adjusted applicable federal short-term, mid-term, and long-term rates are set forth for the month of December 2004.

Section 642.–Special Rules for Credits and Deductions

Federal short-term, mid-term, and long-term rates are set forth for the month of December 2004.

Section 807.–Rules for Certain Reserves

The adjusted applicable federal short-term, mid-term, and long-term rates are set forth for the month of December 2004.

Section 846.–Discounted Unpaid Losses Defined

The adjusted applicable federal short-term, mid-term, and long-term rates are set forth for the month of December 2004.

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 December 2004.

Section 7520.–Valuation Tables

The adjusted applicable federal short-term, mid-term, and long-term rates are set forth for the month of December 2004.

Section 7872.–Treatment of Loans With Below-Market Interest Rates

The adjusted applicable federal short-term, mid-term, and long-term rates are set forth for the month of December 2004.

Section 1274.–Determination of Issue Price in the Case of Certain Debt Instruments Issued for Property

Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 642, 1274, 1288, and other sections of the Code, tables set forth the rates for December 2004.

This revenue ruling provides various prescribed rates for federal income tax purposes for December 2004 (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 2005 interest rate for sections 846 and 807.

——————————————————–
               REV. RUL. 2004-106 TABLE 1
    Applicable Federal Rates (AFR) for December 2004
                 Period for Compounding
            Annual      Semiannual Quarterly Monthly
Short-term
       AFR 2.48%       2.46%       2.45%      2.45%

110% AFR 2.73%       2.71%       2.70%      2.69%
120% AFR 2.97%       2.95%       2.94%      2.93%
130% AFR 3.23%       3.20%       3.19%      3.18%

Mid-term
       AFR 3.56%       3.53%       3.51%      3.50%
110% AFR 3.92%       3.88%       3.86%      3.85%
120% AFR 4.28%       4.24%       4.22%      4.20%
130% AFR 4.64%       4.59%       4.56%      4.55%
150% AFR 5.37%       5.30%       5.27%      5.24%
175% AFR 6.28%       6.18%       6.13%      6.10%
Long-term
       AFR 4.68%       4.63%       4.60%      4.59%
110% AFR 5.15%       5.09%       5.06%      5.04%
120% AFR 5.64%       5.56%       5.52%      5.50%
130% AFR 6.11%       6.02%       5.98%      5.95%
——————————————————–

—————————————————————
                  REV. RUL. 2004-106 TABLE 2
                Adjusted AFR for December 2004
                    Period for Compounding
                         Annual Semiannual Quarterly Monthly
Short-term adjusted AFR 1.88%   1.87%       1.87%      1.86%
Mid-term adjusted AFR    2.84%   2.82%       2.81%      2.80%
Long-term adjusted AFR   4.19%   4.15%       4.13%      4.11%
—————————————————————

——————————————————————————-
                          REV. RUL. 2004-106 TABLE 3
                   Rates Under Section 382 for December 2004
Adjusted federal long-term rate for the current month                     4.19%
Long-term tax-exempt rate for ownership changes during the current month 4.27%
(the highest of the adjusted federal long-term rates for the current
month and the prior two months.)
——————————————————————————-

——————————————————————————-
                          REV. RUL. 2004-106 TABLE 4
       Appropriate Percentages Under Section 42(b)(2) for December 2004
Appropriate percentage for the 70% present value low-income housing       7.96%
credit
Appropriate percentage for the 30% present value low-income housing       3.41%
credit
——————————————————————————-

——————————————————————————-

                          REV. RUL. 2004-106 TABLE 5
                   Rate Under Section 7520 for December 2004
Applicable federal rate for determining the present value of an annuity, 4.20%
an interest for life or a term of years, or a remainder or
  reversionary interest
——————————————————————————-

——————————————————————————-
REV. RUL. 2004-106 TABLE 6
Applicable rate of interest for 2005 for purposes of sections 846 and 4.44%
807
——————————————————————————-

Rev. Rul. 2004-106, 2004-49 I.R.B. 893

Bookmark to: