Part I. Rulings and Decisions Under the Internal Revenue Code of 1986

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.

This revenue ruling provides in Table 1 the bond factor amounts for calculating the amount of bond considered satisfactory under § 42(j)(6) for dispositions of qualified low-income buildings or interests therein during the period January through March 1999.

Section 42.–Low-Income Housing Credit

The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the month of April 1999. See Rev. Rul. 99–17, page 4.

Low-income housing credits; satis- factory bond; “bond factor” amounts for the period January through March 1999. This ruling announces the monthly bond factor amounts to be used by taxpayers who dispose of qualified low-in

come buildings or interests therein during the period January through March 1999.

Rev. Rul. 99–18

In Rev. Rul. 90–60, 1990–2 C.B. 3, 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

Table 1

Rev. Rul. 99–18

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 Disposition 1987 1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999

Jan ’99 44.10 57.48 70.98 72.56 74.67 77.09 79.54 81.87 84.18 86.70 89.33 92.33 92.81 Feb ’99 44.10 57.48 70.98 72.35 74.45 76.85 79.29 81.60 83.90 86.40 89.00 91.92 92.81 Mar ’99 44.10 57.48 70.98 72.14 74.24 76.62 79.05 81.35 83.63 86.11 88.69 91.56 92.81

For a list of bond factor amounts applicable to dispositions occurring during other calendar years, see the following revenue rulings: Rev. Rul. 98–3, 1998–2 I.R.B. 4, for dispositions occurring during the calendar years 1996 and 1997; Rev. Rul. 98–13, 1998–11 I.R.B. 4, for dispositions occurring during the period January through March 1998; Rev. Rul. 98–31, 1998–25 I.R.B. 4, for dispositions occurring during the period April through June 1998; Rev. Rul. 98–45, 1998–38 I.R.B. 4, for dispositions occurring during the period July through September 1998; and Rev. Rul. 99–1, 1999–2 I.R.B. 4, for dispositions occurring during the period October through December 1998.

DRAFTING INFORMATION

The principal author of this revenue ruling is Gregory Doran of the Office of Assistant Chief Counsel (Passthroughs and Special Industries). For further information regarding this revenue ruling, contact Mr. Doran on (202) 622-3040 (not a toll-free call).

Section 280G.—Golden Parachute Payments

Federal short-term, mid-term, and long-term rates are set forth for the month of April 1999. See Rev. Rul. 99–17, page 4.

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 April 1999. See Rev. Rul. 99–17, page 4.

Section 412.—Minimum Funding Standards

The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the month of April 1999. See Rev. Rul. 99–17, page 4.

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 April 1999. See Rev. Rul. 99–17, page 4

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 April 1999. See Rev. Rul. 99–17, page 4.

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 April 1999. See Rev. Rul. 99–17, page 4.

1999–14 I.R.B. 3 April 5, 1999

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 April 1999. See Rev. Rul. 99–17, page 4.

Section 642.—Special Rules for Credits and Deductions

Federal short-term, mid-term, and long-term rates are set forth for the month of April 1999. See Rev. Rul. 99–17, page 4.

Section 807.—Rules for Certain Reserves

The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the month of April 1999. See Rev. Rul. 99–17, page 4.

Section 846.—Discounted Unpaid Losses Defined

The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the month of April 1999. See Rev. Rul. 99–17, page 4.

Section 911.—Citizens or Residents of the United States Living Abroad

26 CFR 1.911–1: Partial exclusion for earned income sources within a foreign country and foreign housing costs.

Guidance is provided to individuals who fail to meet the eligibility requirements of section 911(d)(1) of the Internal Revenue Code because adverse conditions in a foreign country preclude the individual from meeting those requirements. A current list of countries and the dates of those countries are subject to the section 911(d)(4) waiver is provided. See Rev. Proc. 99–20, page 7.

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.)

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 April 1999.