REVENUE RULE 94-55
1994-2 C.B. 193, 1994-36 I.R.B. 13.
Internal Revenue Service
Revenue Ruling
FEDERAL RATES; ADJUSTED FEDERAL RATES; ADJUSTED FEDERAL LONG-TERM RATE; AND THE LONG-TERM EXEMPT RATE
Published August 18, 1994
Section 1274. - Determination of Issue Price in the Case of Certain Debt Instruments Issued for Property
(See Also Sections 42, 280G, 382, 412, 467, 468, 483, 807, 846, 1288, 7520, 7872.)
Federal rates; adjusted federal rates; adjusted federal long-term rate; and the long-term
exempt rate. For purposes of sections 1274, 1288, 382, and other sections of the Code,
tables set forth the rates for September 1994.
This revenue ruling provides various prescribed rates for federal income tax purposes for September 1994 (the current month). Table I 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 APR) 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. 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. 94-55 TABLE 1
Applicable Federal Rates (AFR) for September 1994
Period for Compounding
Annual Semiannual Quarterly Monthly
Short-Term
| Annual | Semiannual | Quarterly | Monthly | ||
| AFR | 5.86% | 5.78% | 5.74% | 5.71% | |
| 110% | AFR | 6.46% | 6.36% | 6.31% | 6.28% |
| 120% | AFR | 7.06% | 6.94% | 6.88% | 6.84% |
Mid-Term
| Annual | Semiannual | Quarterly | Monthly | ||
| AFR | 7.05% | 6.93% | 6.87% | 6.83% | |
| 110% | AFR | 7.77% | 7.62% | 7.55% | 7.50% |
| 120% | AFR | 8.49% | 8.32% | 8.24% | 8.18% |
| 150% | AFR | 10.67% | 10.40% | 10.27% | 10.18% |
| 175% | AFR | 12.50% | 12.13% | 11.95% | 11.83% |
Long-Term
| Annual | Semiannual | Quarterly | Monthly | ||
| AFR | 7.63% | 7.49% | 7.42% | 7.38% | |
| 110% | AFR | 8.41% | 8.24% | 8.16% | 8.10% |
| 120% | AFR | 9.19% | 8.99% | 8.89% | 8.83% |
REV. RUL. 94-55 TABLE 2
Adjusted AFR for September 1994
Period for Compounding
| Annual | Semiannual | Quarterly | Monthly | |
| Short-term adjusted AFR | 4.12% | 4.08% | 4.06% | 4.05% |
| Annual | Semiannual | Quarterly | Monthly | |
| Mid-term adjusted AFR | 4.98% | 4.92% | 4.89% | 4.87% |
| Annual | Semiannual | Quarterly | Monthly | |
| Long-term adjusted AFR | 6.05% | 5.96% | 5.92% | 5.89% |
REV. RUL. 94-55 TABLE 3
Rates Under Section 382 for September 1994
Adjusted federal long-term rate for the current month 6.05%
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.)
6.05%
REV. RUL. 94-55 TABLE 4
Appropriate Percentages Under Section 42(b)(2)for September 1994
Appropriate percentage for the 70% present value low-income housing credit 8.73%
Appropriate percentage for the 30% present value low-income housing credit 3.74%
REV. RUL. 94-55 TABLE 5
Rate Under Section 7520 for September 1994
Applicable federal rate for determining the present value of an annuity, an interest for
life or a term of years, or a remainder or reversionary interest 8.4%
Rev. Rul. 94-55, 1994-2 C.B. 193, 1994-36 I.R.B. 13.