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Revenue Ruling on Issue Price for Certain Debt Instruments Issued for Property

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Washington, D.C. (October 21, 2012)

By Jeff Stimpson

The IRS has issued a revenue ruling on the determination of issue prices in the case of certain debt instruments issued for property

Revenue Ruling 12-28 provides various prescribed rates for federal income tax purposes for November 2012, including:

• 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;

• The short-term, mid-term and long-term adjusted applicable federal rates (adjusted AFR) for the current month for purposes of Section 1288(b);

• The adjusted federal long-term rate and long-term tax-exempt rate described in Section 382(f);

• 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 (though under 42(b)(2), the applicable percentage for non-federally subsidized new buildings placed in service after July 30, 2008, and before Dec. 31, 2013, shall not be less than 9 percent); and,

• 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.

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