§ 1.382-12. Determination of adjusted Federal long-term rate.
277 words·~1 min read·
/us/cfr/t26/s§ 1.382-12·A research copy — for the controlling text, always check the official state or federal source. Not legal advice.
(a)In general. The long-term tax-exempt rate for an ownership change is the highest of the adjusted Federal long-term rates in effect for any month in the 3-calendar-month period ending with the calendar month in which the change date occurs. For purposes of the previous sentence, the adjusted Federal long-term rate is the Federal long-term rate determined under section 1274(d) (without regard to paragraphs
(2)and
(3)thereof), adjusted for differences between rates on long-term taxable and tax-exempt obligations. The Secretary calculates the adjusted Federal long-term rate as provided in paragraph
(b)of this section. The Internal Revenue Service publishes the long-term tax-exempt rate and the adjusted Federal long-term rate for each month in the Internal Revenue Bulletin (see § 601.601(d)(2)(ii) of this chapter).
(b)Adjusted Federal long-term rate. The adjusted Federal long-term rate for a calendar month is the product of the Federal long-term rate determined under section 1274(d) for that month, based on annual compounding, multiplied by the adjustment factor described in paragraph
(c)of this section.
(c)Adjustment factor. The adjustment factor is a percentage equal to—
(1)The excess of 100 percent, over
(2)The product of—
(i)59 percent, and
(ii)The sum of the maximum rate in effect under section 1 applicable to individuals and the maximum rate in effect under section 1411 applicable to individuals for the month to which the adjusted applicable Federal rate applies.
(d)Effective/applicability date. The rules of this section apply to the determination of the long-term tax-exempt rate and the adjusted Federal long-term rate beginning with the rates determined during August 2016 that apply during September 2016. [T.D. 9763, 81 FR 24483, Apr. 26, 2016]
Connections1 off-index
1 reference not yet in our index
- T.D. 9763
Citation graph
cites case law
§ 1.382-12
Determination of adjusted Federal long-term rate.
Treas. Dec.T.D. 9763
Cites 1Cited by 0 across 0 sources