Internal Revenue Service
Revenue Ruling
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smLOW-INCOME HOUSING CREDIT; SATISFACTORY BOND; "BOND FACTOR" AMOUNTS FOR THE PERIOD APRIL THROUGH JUNE 2001
Published: April 30, 2001
Section 42.--Low-Income Housing Credit
Low-income housing credit; satisfactory bond; "bond factor" amounts for the period April through June 2001. 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 April through June 2001.
In Rev. Rul. 90-60, 1990-2 C.B. 4, 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 § 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 § 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 § 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 April through June 2001.
Table 1
Rev. Rul. 2001-19
Monthly Bond Factor Amounts for Dispositions Expressed As a Percentage of Total
Credits
Calendar Year Building Placed in Service or, if Section 42(f)(1)
Election Was Made, the Succeeding Calendar Year
Month of 1987
1988 1989
1990 1991
1992 1993
1994 1995
1996 1997
Disposition
Apr '01
20.36 37.41 51.71 63.80 74.03 75.46 77.76 79.98 82.22 84.67 87.27
May '01
20.36 37.41 51.71 63.80 74.03 75.25 77.54 79.75 81.98 84.42 87.01
Jun '01
20.36 37.41 51.71 63.80 74.03 75.05 77.32 79.52 81.75 84.18 86.76
Table 1 (cont'd)
Rev. Rul. 2001-19
Monthly Bond Factor Amounts for Dispositions Expressed As a Percentage of Total
Credits
Calendar Year Building Placed in Service or, if Section 42(f)(1)
Election
Was Made, the Succeeding Calendar Year
Month of
1998
1999 2000
2001
Disposition
Apr '01 90.15
93.01
95.60
97.21
May '01 89.87
92.71
95.31
97.21
Jun '01 89.61
92.44
95.05
97.21
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, and Rev. Rul. 2001-2, 2001-2 I.R.B. 255. For dispositions occurring during the period January through March 2001, see Rev. Rul. 2001-10, 2001-10 I.R.B. 755.
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. 2001-19, 2001-18 I.R.B. 1143