Part III

Administrative, Procedural, and Miscellaneous

26 CFR 1.199A-11: Wage limitation for the section 199A(g) deduction

(Also: [XX, XXX, XXX])

Rev. Proc. 2019-XX

2016-31, Notice 2017-04, and Notice 2018-59 are modified.

This notice provides guidance on the corporate bond monthly yield curve, the corresponding spot segment rates used under § 417(e)(3), and the 24-month average segment rates under § 430(h)(2) of the Internal Revenue Code. In addition, this notice provides guidance as to the interest rate on 30-year Treasury securities under § 417(e)(3)(A)(ii)(II) as in effect for plan years beginning before 2008 and the 30year Treasury weighted average rate under § 431(c)(6)(E)(ii)(I).

YIELD CURVE AND SEGMENT RATES

Section 430 specifies the minimum funding requirements that apply to single-employer plans (except for CSEC plans under § 414(y)) pursuant to § 412. Section 430(h)(2) specifies the interest rates that must be used to determine a plan’s target normal cost and funding target. Under this provision, present value is generally determined using three 24-month average interest rates (“segment rates”), each of which applies to cash flows during specified periods. To the extent provided under § 430(h)(2) (C)(iv), these segment rates are adjusted by the applicable percentage of the 25year average segment rates for the period

Bulletin No. 2019–31 489 July 29, 2019

ending September 30 of the year preceding the calendar year in which the plan year begins. ¹ However, an election may be made under § 430(h)(2)(D)(ii) to use the monthly yield curve in place of the segment rates.

Notice 2007-81, 2007-44 I.R.B. 899, provides guidelines for determining the monthly corporate bond yield curve, and the 24-month average corporate bond segment rates used to compute the target normal cost and the funding target. Consistent with the methodology specified in Notice 2007-81, the monthly

corporate bond yield curve derived from June 2019 data is in Table 2019-6 at the end of this notice. The spot first, second, and third segment rates for the month of June 2019 are, respectively, 2.41, 3.51, and 4.16.

The 24-month average segment rates determined under § 430(h)(2)(C)(i) through (iii) must be adjusted pursuant to § 430(h) (2)(C)(iv) to be within the applicable minimum and maximum percentages of the corresponding 25-year average segment rates. For plan years beginning before 2021, the applicable minimum percentage is 90%

and the applicable maximum percentage is 110%. The 25-year average segment rates for plan years beginning in 2018 and 2019 were published in Notice 2017-50, 201741 I.R.B. 280, and Notice 2018-73, 201840 I.R.B. 526, respectively.

24-MONTH AVERAGE CORPORATE BOND SEGMENT RATES

The three 24-month average corporate bond segment rates applicable for July 2019 without adjustment for the 25-year average segment rate limits are as follows:

24-Month Average Segment Rates Without 25-Year Average Adjustment Applicable Month First Segment Second Segment Third Segment July 2019 2.76 3.95 4.43

Based on § 430(h)(2)(C)(iv), the 2019, adjusted to be within the applicable 24-month averages applicable for July minimum and maximum percentages of

the corresponding 25-year average segment rates, are as follows:

Adjusted 24-Month Average Segment Rates For Plan Years

Beginning In Applicable Month First Segment Second Segment Third Segment

2018 July 2019 3.92 5.52 6.29

2019 July 2019 3.74 5.35 6.11

30-YEAR TREASURY SECURITIES INTEREST RATES

Section 431 specifies the minimum funding requirements that apply to multiemployer plans pursuant to § 412. Section 431(c)(6)(B) specifies a minimum amount for the full-funding limitation described in § 431(c)(6)(A), based on the plan’s current liability. Section 431(c)(6)(E)(ii)(I) pro

For Plan Years Beginning In

vides that the interest rate used to calculate current liability for this purpose must be no more than 5 percent above and no more than 10 percent below the weighted average of the rates of interest on 30-year Treasury securities during the four-year period ending on the last day before the beginning of the plan year. Notice 88-73, 1988-2 C.B. 383, provides guidelines for determining the weighted average interest rate. The rate

Treasury Weighted Average Rates

30-Year Treasury Weighted Average

of interest on 30-year Treasury securities for June 2019 is 2.57 percent. The Service determined this rate as the average of the daily determinations of yield on the 30year Treasury bond maturing in May 2049. For plan years beginning in July 2019, the weighted average of the rates of interest on 30-year Treasury securities and the permissible range of rates used to calculate current liability are as follows:

Permissible Range

90% to 105%

July 2019 2.93 2.63 to 3.07

1 Pursuant to § 433(h)(3)(A), the 3rd segment rate determined under § 430(h)(2)(C) is used to determine the current liability of a CSEC plan (which is used to calculate the minimum amount of the full funding limitation under § 433(c)(7)(C)).

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MINIMUM PRESENT VALUE SEGMENT RATES

In general, the applicable interest rates

under § 417(e)(3)(D) are segment rates computed without regard to a 24-month average. Notice 2007-81 provides guidelines for determining the minimum pres

ent value segment rates. Pursuant to that notice, the minimum present value segment rates determined for June 2019 are as follows:

Minimum Present Value Segment Rates Month First Segment Second Segment Third Segment June 2019 2.41 3.51 4.16

DRAFTING INFORMATION

The principal author of this notice is Tom Morgan of the Office of the Asso

ciate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes). However, other personnel from the IRS participated in the development

of this guidance. For further information regarding this notice, contact Mr. Morgan at 202-317-6700 or Paul Stern at 202-3178702 (not toll-free numbers).

Bulletin No. 2019–31 491 July 29, 2019

Table 2019-6 Monthly Yield Curve for June 2019

Derived from June 2019 Data

Maturity Yield Maturity Yield Maturity Yield Maturity Yield Maturity Yield 0.5 2.38 20.5 3.98 40.5 4.18 60.5 4.26 80.5 4.29 1.0 2.37 21.0 3.99 41.0 4.19 61.0 4.26 81.0 4.29 1.5 2.37 21.5 4.00 41.5 4.19 61.5 4.26 81.5 4.29 2.0 2.36 22.0 4.01 42.0 4.19 62.0 4.26 82.0 4.30 2.5 2.37 22.5 4.02 42.5 4.19 62.5 4.26 82.5 4.30 3.0 2.38 23.0 4.02 43.0 4.20 63.0 4.26 83.0 4.30 3.5 2.40 23.5 4.03 43.5 4.20 63.5 4.26 83.5 4.30 4.0 2.44 24.0 4.04 44.0 4.20 64.0 4.26 84.0 4.30 4.5 2.49 24.5 4.04 44.5 4.20 64.5 4.27 84.5 4.30 5.0 2.55 25.0 4.05 45.0 4.21 65.0 4.27 85.0 4.30 5.5 2.62 25.5 4.06 45.5 4.21 65.5 4.27 85.5 4.30 6.0 2.69 26.0 4.06 46.0 4.21 66.0 4.27 86.0 4.30 6.5 2.78 26.5 4.07 46.5 4.21 66.5 4.27 86.5 4.30 7.0 2.86 27.0 4.07 47.0 4.21 67.0 4.27 87.0 4.30 7.5 2.95 27.5 4.08 47.5 4.22 67.5 4.27 87.5 4.30 8.0 3.04 28.0 4.09 48.0 4.22 68.0 4.27 88.0 4.30 8.5 3.12 28.5 4.09 48.5 4.22 68.5 4.27 88.5 4.30 9.0 3.20 29.0 4.10 49.0 4.22 69.0 4.27 89.0 4.30 9.5 3.28 29.5 4.10 49.5 4.22 69.5 4.28 89.5 4.30 10.0 3.35 30.0 4.11 50.0 4.23 70.0 4.28 90.0 4.30 10.5 3.42 30.5 4.11 50.5 4.23 70.5 4.28 90.5 4.31 11.0 3.48 31.0 4.12 51.0 4.23 71.0 4.28 91.0 4.31 11.5 3.54 31.5 4.12 51.5 4.23 71.5 4.28 91.5 4.31 12.0 3.59 32.0 4.13 52.0 4.23 72.0 4.28 92.0 4.31 12.5 3.64 32.5 4.13 52.5 4.23 72.5 4.28 92.5 4.31 13.0 3.68 33.0 4.13 53.0 4.24 73.0 4.28 93.0 4.31 13.5 3.72 33.5 4.14 53.5 4.24 73.5 4.28 93.5 4.31 14.0 3.75 34.0 4.14 54.0 4.24 74.0 4.28 94.0 4.31 14.5 3.78 34.5 4.15 54.5 4.24 74.5 4.28 94.5 4.31 15.0 3.81 35.0 4.15 55.0 4.24 75.0 4.29 95.0 4.31 15.5 3.83 35.5 4.15 55.5 4.24 75.5 4.29 95.5 4.31 16.0 3.86 36.0 4.16 56.0 4.24 76.0 4.29 96.0 4.31 16.5 3.88 36.5 4.16 56.5 4.25 76.5 4.29 96.5 4.31 17.0 3.89 37.0 4.16 57.0 4.25 77.0 4.29 97.0 4.31 17.5 3.91 37.5 4.17 57.5 4.25 77.5 4.29 97.5 4.31 18.0 3.92 38.0 4.17 58.0 4.25 78.0 4.29 98.0 4.31 18.5 3.94 38.5 4.17 58.5 4.25 78.5 4.29 98.5 4.31 19.0 3.95 39.0 4.18 59.0 4.25 79.0 4.29 99.0 4.31 19.5 3.96 39.5 4.18 59.5 4.25 79.5 4.29 99.5 4.31 20.0 3.97 40.0 4.18 60.0 4.26 80.0 4.29 100.0 4.31

July 29, 2019 492 Bulletin No. 2019–31