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

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 2012. See Rev. Rul. 2012-21, page 123.

Section 280G.—Golden Parachute Payments

Federal short-term, mid-term, and long-term rates are set forth for the month of August 2012. See Rev. Rul. 2012-21, page 123.

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 2012. See Rev. Rul. 2012-21, page 123.

Section 412.—Minimum Funding Standards

The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the month of August 2012. See Rev. Rul. 2012-21, page 123.

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 2012. See Rev. Rul. 2012-21, page 123.

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 2012. See Rev. Rul. 2012-21, page 123.

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 2012. See Rev. Rul. 2012-21, page 123.

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 2012. See Rev. Rul. 2012-21, page 123.

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 2012. See Rev. Rul. 2012-21, page 123.

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 2012. See Rev. Rul. 2012-21, page 123.

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 2012. See Rev. Rul. 2012-21, page 123.

Section 1274.—Determi- nation of Issue Price in the Case of Certain Debt Instru- ments 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 382, 642, 1274, 1288, and other sections of the Code, tables set forth the rates for August 2012.

Rev. Rul. 2012–21

This revenue ruling provides various prescribed rates for federal income tax purposes for August 2012 (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)(1) for buildings placed in service during the current month. However, under section 42(b)(2), the applicable percentage for non-federally subsidized new buildings placed in service after July 30, 2008, and before December 31, 2013, shall not be less than 9%. 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.

2012–32 I.R.B. 123 August 6, 2012

REV. RUL. 2012–21 TABLE 1

Applicable Federal Rates (AFR) for August 2012

Period for Compounding

Annual Semiannual Quarterly Monthly

Short-term

AFR .25% .25% .25% .25% 110% AFR .28% .28% .28% .28% 120% AFR .30% .30% .30% .30% 130% AFR .33% .33% .33% .33%

Mid-term

AFR .88% .88% .88% .88% 110% AFR .97% .97% .97% .97% 120% AFR 1.06% 1.06% 1.06% 1.06% 130% AFR 1.14% 1.14% 1.14% 1.14% 150% AFR 1.32% 1.32% 1.32% 1.32% 175% AFR 1.55% 1.54% 1.54% 1.54%

Long-term

AFR 2.23% 2.22% 2.21% 2.21% 110% AFR 2.45% 2.44% 2.43% 2.43% 120% AFR 2.68% 2.66% 2.65% 2.65% 130% AFR 2.91% 2.89% 2.88% 2.87%

REV. RUL. 2012–21 TABLE 2

Adjusted AFR for August 2012

Period for Compounding

Annual Semiannual Quarterly Monthly

Short-term adjusted .25% .25% .25% .25% AFR

Mid-term adjusted AFR 1.07% 1.07% 1.07% 1.07%

Long-term adjusted 3.01% 2.99% 2.98% 2.97% AFR

REV. RUL. 2012–21 TABLE 3

Rates Under Section 382 for August 2012

Adjusted federal long-term rate for the current month 3.01%

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.) 3.06%

REV. RUL. 2012–21 TABLE 4

Appropriate Percentages Under Section 42(b)(1) for August 2012

Note: Under Section 42(b)(2), the applicable percentage for non-federally subsidized new buildings placed in service after July 30, 2008, and before December 31, 2013, shall not be less than 9%.

Appropriate percentage for the 70% present value low-income housing credit 7.36%

Appropriate percentage for the 30% present value low-income housing credit 3.15%

August 6, 2012 124 2012–32 I.R.B.

REV. RUL. 2012–21 TABLE 5

Rate Under Section 7520 for August 2012

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 1.0%

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 2012. See Rev. Rul. 2012-21, page 123.

Section 1288.—Treatment of Original Issue Discount on Tax-Exempt Obligations

The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the month of August 2012. See Rev. Rul. 2012-21, page 123.

Section 7520.—Valuation Tables

The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the month of August 2012. See Rev. Rul. 2012-21, page 123.

2012–32 I.R.B. 125 August 6, 2012