Internal Revenue Service
Revenue Ruling
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smRev. Rul. 2003-94
Rev. Rul. 2003-94, 2003-33 I.R.B. 357, 2003-2 C.B. 357
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: July 17, 2003
Published: August 18, 2003
Section 42.--Low-Income Housing Credit
The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the month of August 2003.
Section 280G.--Golden Parachute Payments
Federal short-term, mid-term, and long-term rates are set forth for the month of August 2003.
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 August 2003.
Section 412.--Minimum Funding Standards
The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the month of August 2003.
Section 467.--Certain Payments for the Use of Property or Services
The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the month of August 2003.
Section 468.--Special Rules for Mining and Solid Waste Reclamation and Closing Costs
The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the month of August 2003.
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 August 2003.
Section 483.--Interest on Certain Deferred Payments
The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the month of August 2003.
Section 642.--Special Rules for Credits and Deductions
Federal short-term, mid-term, and long-term rates are set forth for the month of August 2003.
Section 807.--Rules for Certain Reserves
The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the month of August 2003.
Section 846.--Discounted Unpaid Losses Defined
The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the month of August 2003.
Section 1288.--Treatment of Original Issue Discounts on Tax-Exempt Obligations
The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the month of August 2003.
Section 7520.--Valuation Tables
The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the month of August 2003.
Section 7872.--Treatment of Loans With Below-Market Interest Rates
The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the month of August 2003.
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, 1274, 1288, and other sections of the Code, tables set forth the rates for August 2003.
Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 1274, 1288, and other sections of the Code, tables set forth the rates for August 2003.
This revenue ruling provides various prescribed rates for federal income tax purposes for August 2003 (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. Finally, Table 5 contains the federal rate for determining the present value of annuity, an interest for life or for a term of years, or a remainder or a reversionary interest for purposes of section 7520.
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REV. RUL. 2003-94 TABLE 1
Applicable Federal Rates (AFR) for August 2003
Period for Compounding
Annual Semiannual Quarterly Monthly
Short-Term
AFR 1.21% 1.21% 1.21% 1.21%
110% AFR 1.33% 1.33% 1.33% 1.33%
120% AFR 1.46% 1.45% 1.45% 1.45%
130% AFR 1.58% 1.57% 1.57% 1.56%
Mid-Term
AFR 2.70% 2.68% 2.67% 2.67%
110% AFR 2.97% 2.95% 2.94% 2.93%
120% AFR 3.25% 3.22% 3.21% 3.20%
130% AFR 3.51% 3.48% 3.46% 3.46%
150% AFR 4.06% 4.02% 4.00% 3.99%
175% AFR 4.74% 4.69% 4.66% 4.64%
Long-Term
AFR 4.36% 4.31% 4.29% 4.27%
110% AFR 4.80% 4.74% 4.71% 4.69%
120% AFR 5.24% 5.17% 5.14% 5.12%
130% AFR 5.68% 5.60% 5.56% 5.54%
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REV. RUL. 2003-94 TABLE 2
Adjusted AFR for August 2003
Period for Compounding
Annual Semiannual Quarterly Monthly
Short-term adjusted AFR 1.08% 1.08% 1.08% 1.08%
Mid-term adjusted AFR 2.37% 2.36% 2.35% 2.35%
Long-term adjusted AFR 4.12% 4.08% 4.06% 4.05%
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REV. RUL. 2003-94 TABLE 3
Rates Under Section 382 for August 2003
Adjusted federal long-term rate for the current month 4.12%
Long-term tax-exempt rate for ownership changes during the current month 4.35%
(the highest of the adjusted federal long-term rates for the month and
the prior two months.)
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REV. RUL. 2003-94 TABLE 4
Appropriate Percentages Under Section 42(b)(2) for August 2003
Appropriate percentage for the 70% present value low-income housing 7.82%
credit
Appropriate percentage for the 30% present value low-income housing 3.35%
credit
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REV. RUL. 2003-94 TABLE 5
Rate Under Section 7520 for August 2003
Applicable federal rate for determining the present value of an annuity, 3.2%
an interest for life or a term of years, or a remainder or reversionary
interest
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Rev. Rul. 2003-94, 2003-33 I.R.B. 357, 2003-2 C.B. 357