- Community
- Research
- Forms, Rates & Tables
- Government
- Executive
- Judicial
- Legislative
- Treasury
- Comments
- Continuing Professional Education
- Determination Letter
- Email Chief Counsel Advice
- Field Service Advice
- Forms and Instructions
- General Counsel Memoranda
- IRS Announcements
- IRS Fact Sheet
- IRS Forms
- IRS Legal Memoranda
- IRS Notices
- Information Release
- Internal Revenue Code
- Letter Rulings
- Publications
- Regulations
- Revenue Procedures
- Revenue Rulings
- Technical Advice Memoranda
- Treasury Decisions
- Management
- Marketing
- Planning
- News
- Articles
- Case Studies
- Technical Reports
December 7520 Rate Increases to 1.6%
Summary
For purposes of determining the present value of an annuity, an interest for life or a term of years, or a remainder or a reversionary interest, Revenue Ruling 2011-31 indicates the applicable federal rate under section 7520 for December 2011 is 1.6%; up 0.2% from the November and October rates of 1.4%.
Planners should pay particular attention to the effect of historically low rates on donors' deductions for certain split-interest gift vehicles and, in certain cases, their ability to qualify for them.
Rev. Rul. 2011-31
Full Text:
Part I
Section 1274. -- Determination of Issue Price in the Case of Certain Debt Instruments Issued for Property
(Also Sections 42, 280G, 382, 412, 467, 468, 482, 483, 642, 807, 846, 1288, 7520, 7872.)
This revenue ruling provides various prescribed rates for federal income tax purposes for December 2011 (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, and before December 31, 2013, shall not be less than 9%. 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 contains the 2012 interest rate for sections 846 and 807.
REV. RUL. 2011-31 TABLE 1
Applicable Federal Rates (AFR) for December 2011
_____________________________________________________________________
Period for Compounding
_____________________________________________
Annual Semiannual Quarterly Monthly
_____________________________________________________________________
Short-term
AFR .20% .20% .20% .20%
110% AFR .22% .22% .22% .22%
120% AFR .24% .24% .24% .24%
130% AFR .26% .26% .26% .26%
Mid-term
AFR 1.27% 1.27% 1.27% 1.27%
110% AFR 1.40% 1.40% 1.40% 1.40%
120% AFR 1.53% 1.52% 1.52% 1.52%
130% AFR 1.66% 1.65% 1.65% 1.64%
150% AFR 1.92% 1.91% 1.91% 1.90%
175% AFR 2.23% 2.22% 2.21% 2.21%
Long-term
AFR 2.80% 2.78% 2.77% 2.76%
110% AFR 3.08% 3.06% 3.05% 3.04%
120% AFR 3.37% 3.34% 3.33% 3.32%
130% AFR 3.64% 3.61% 3.59% 3.58%
REV. RUL. 2011-31 TABLE 2
Adjusted AFR for December 2011
_____________________________________________________________________
Period for Compounding
_____________________________________________
Annual Semiannual Quarterly Monthly
_____________________________________________________________________
Short-term
adjusted AFR .45% .45% .45% .45%
Mid-term
adjusted AFR 1.69% 1.68% 1.68% 1.67%
Long-term
adjusted AFR 3.55% 3.52% 3.50% 3.49%
REV. RUL. 2011-31 TABLE 3
Rates Under Section 382 for December 2011
_____________________________________________________________________
Adjusted federal long-term rate for the current 3.55%
month
Long-term tax-exempt rate for ownership changes 3.55%
during the current month (the highest of the
adjusted federal long-term rates for the current
month and the prior two months.)
REV. RUL. 2011-31 TABLE 4
Appropriate Percentages Under Section 42(b)(1) for December 2011
_____________________________________________________________________
Note: Under Section 42(b)(2), the applicable percentage for
non-federally subsidized new buildings placed in service after
July 30, 2008, and before December 31, 2013, shall not be less
than 9%.
Appropriate percentage for the 70% present value 7.47%
low-income housing credit
Appropriate percentage for the 30% present value 3.20%
low-income housing credit
REV. RUL. 2011-31 TABLE 5
Rate Under Section 7520 for December 2011
_____________________________________________________________________
Applicable federal rate for determining the 1.6%
present value of an annuity, an interest for life
or a term of years, or a remainder or reversionary
interest
REV. RUL. 2011-31 TABLE 6
Rates Under Sections 846 and 807
_____________________________________________________________________
Applicable rate of interest for 2012 for purposes 2.89%
of sections 846 and 807
Add comment
Comments