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 February 2014. See Rev. Rul. 2014–6, page 510.

Section 280G.—Golden Parachute Payments

Federal short-term, mid-term, and long-term rates are set forth for the month of February 2014. See Rev. Rul. 2014–6, page 510.

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 February 2014. See Rev. Rul. 2014–6, page 510.

Section 412.—Minimum Funding Standards

The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the month of February 2014. See Rev. Rul. 2014–6, page 510.

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 February 2014. See Rev. Rul. 2014–6, page 510.

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 February 2014. See Rev. Rul. 2014–6, page 510.

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 February 2014. See Rev. Rul. 2014–6, page 510.

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 February 2014. See Rev. Rul. 2014–6, page 510.

Section 642.—Special Rules for Credits and Deductions

Federal short-term, mid-term, and long-term rates are set forth for the month of February 2014. See Rev. Rul. 2014–6, page 510.

Section 807.—Rules for Certain Reserves

The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the month of February 2014. See Rev. Rul. 2014–6, page 510.

Section 846.—Discounted Unpaid Losses Defined

The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the month of February 2014. See Rev. Rul. 2014–6, page 510.

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.)

Rev. Rul. 2014–6

This revenue ruling provides various prescribed rates for federal income tax purposes for February 2014 (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 longterm 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, with respect to housing credit dollar amount allocations made before January 1, 2014, 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 of a reversionary interest for purposes of section 7520.

February 10, 2014 510 Bulletin No. 2014–7

REV. RUL. 2014–6 TABLE 1

Applicable Federal Rates (AFR) for February 2014

Period for Compounding

Annual Semiannual Quarterly Monthly

Short-term

AFR .30% .30% .30% .30%

110% AFR .33% .33% .33% .33%

120% AFR .36% .36% .36% .36%

130% AFR .39% .39% .39% .39%

Mid-term

AFR 1.97% 1.96% 1.96% 1.95%

110% AFR 2.17% 2.16% 2.15% 2.15%

120% AFR 2.36% 2.35% 2.34% 2.34%

130% AFR 2.57% 2.55% 2.54% 2.54%

150% AFR 2.96% 2.94% 2.93% 2.92%

175% AFR 3.46% 3.43% 3.42% 3.41%

Long-term

AFR 3.56% 3.53% 3.51% 3.50%

110% AFR 3.92% 3.88% 3.86% 3.85%

120% AFR 4.28% 4.24% 4.22% 4.20%

130% AFR 4.64% 4.59% 4.56% 4.55%

REV. RUL. 2014–6 TABLE 2

Adjusted AFR for February 2014

Period for Compounding

Annual Semiannual Quarterly Monthly

Short-term adjusted AFR .30% .30% .30% .30%

Mid-term adjusted AFR 1.56% 1.55% 1.55% 1.55%

Long-term adjusted AFR 3.56% 3.53% 3.51% 3.50%

REV. RUL. 2014–6 TABLE 3

Rates Under Section 382 for February 2014

Adjusted federal long-term rate for the current month 3.56%

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.) 3.56%

REV. RUL. 2014–6 TABLE 4

Appropriate Percentages Under Section 42(b)(1) for February 2014

Note: Under section 42(b)(2), the applicable percentage for non-federally subsidized new buildings placed in service after July 30, 2008, with respect to housing credit dollar amount allocations made before January 1, 2014, shall not be less than 9%.

Appropriate percentage for the 70% present value low-income housing credit 7.64%

Appropriate percentage for the 30% present value low-income housing credit 3.27%

Bulletin No. 2014–7 511 February 10, 2014

REV. RUL. 2014–6 TABLE 5

Rate Under Section 7520 for February 2014

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 2.4%

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 February 2014. See Rev. Rul. 2014–6, page 510.

Section 2010.—Unified Credit Against Estate Tax

This revenue procedure provides an automatic extension of time pursuant to § 301.9100–3 for certain estates without a filing requirement under § 6018(a) to elect portability of the decedent’s unused exclusion

amount for the benefit of the decedent’s surviving spouse pursuant to § 2010(c)(5)(A). The revenue procedure applies to estates of decedents dying after December 31, 2010, and before January 1, 2014, and includes estates of decedents survived by a same-sex spouse that were not eligible to elect portability until after the decision in United States v. Windsor, 570 U.S. ___, 133 S. Ct. 2675 (2013) and the publication of Rev. Rul. 2013–17, 2013–38 I.R.B. 201. See Rev. Proc. 2014–18, page 513.

Section 7520.—Valuation Tables

The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the month of February 2014. See Rev. Rul. 2014–6, page 510.

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 February 2014. See Rev. Rul. 2014–6, page 510.

February 10, 2014 512 Bulletin No. 2014–7