Applicable Federal Rates

<body bgcolor="#FFFFFF" text="#000000" vlink="#660000" alink="#000000" link="#003399"> <center><table width=468 border=0> <tr><td><img src="../images/logoBanner180x165.gif" align=left height=165 width=180 alt="Pillsbury Winthrop Shaw Pittman LLP Tax Page [11K]"> <center><br><br><br><br> <H3>Applicable Federal Rates</H3></center><br clear=left><br><br> <font size=-1>This AFR material has been established and is being maintained as part of the <a href="../index.shtml" target="_top">Pillsbury Winthrop Shaw Pittman <font size=-1>LLP</font> Tax Page</a>, a demonstration World Wide Web project. <a href="mailto:comments@pmstax.com">Comments</a> are welcome on the design or content of this material. For further information, please contact <a href="../cgi/getBio.cgi?WAINWRIGH_CB" target="_top">Brian Wainwright</a>, a tax partner in our Palo Alto office. </font><p><hr><p> <h4>Actual AFR Revenue Rulings Available</h4><p> We now have available the actual IRS Revenue Ruling with the AFRs (and all of the rates derived from those AFRs) for January 1996 through the most recently available month (April 2014). Those Revenue Rulings are in pdf format from the Internal Revenue Bulletin, so you'll need the <a href="http://get.adobe.com/reader/" target="_top">Acrobat Reader</a>, to view or print them.<p> Last updated <b>March 19, 2014 </b> to include <b>April 2014 </b> AFRs.<p> <H4>Available Current AFRs</H4><P> <UL> <LI>Current <A HREF="shortAFR.shtml">Short Term AFRs</A> for instruments having a term of three (3) years or less. <LI>Current <A HREF="midAFR.shtml">Mid Term AFRs</A> for instruments having a term in excess of three (3) years but no greater than nine (9) years. <LI>Current <A HREF="longAFR.shtml">Long Term AFRs</A> for instruments having a term in excess of nine (9) years. <LI>Current <A HREF="exemptAFR.shtml">Adjusted Long Term Rates</A> for determining the <b>Long Term Tax-Exempt Rate</b>, used to compute the annual net operating loss carryover utilization limitation following a change in ownership. <li>Current <a href="cur7520.shtml">Section 7520 Rate</a>, used to value annuities, life interests or interests for terms of years and remainder or reversionary interests. <li>Current <a href="rr201412.pdf ">AFR Revenue Ruling (April 2014)</a>.</UL><p> <h4>AFR Search</h4><p> If your browser supports <b>forms</b>, you can use the <a href="searchAFR.shtml">AFR Search Page</a> to find any of our available AFRs.<p> <h4>Special Note: March 2013 Adjusted AFRs</h4><p> In <a target="_new" href="./n20134.pdf">Notice 2013-4</a>, the IRS announced that it was considering changes in the way it determines the adjusted AFRs and adjusted federal long-term rate published in Tables 2 and 3, respectively, of its monthly AFR revenue ruling. The IRS also announced interim guidance (essentially constraining the adjusted AFR so that it would never be higher than the comparable AFR) that it said would be reflected in its March 2013 AFR ruling. However, the version of that March 2013 AFR ruling originally released by the IRS did not reflect the changes of the interim guidance. The IRS has corrected the March 2013 AFR ruling and it and the corrected rates are available at this site.<p><hr><p> Each month, the U.S. Internal Revenue Service publishes base interest rates known as the applicable federal rates ("AFRs"). These interest rates are used for various purposes under the Internal Revenue Code, particularly the imputed interest and original issue discount rules. The AFRs for a particular month are generally made available during the third or fourth week of the preceeding month; the <b>current</b> rate information presented will ordinarily contain the four (4) most recent available months since, in certain circumstances, the AFR to be utilized is determined as the lowest relevant AFR for the month of the transaction and the two preceding months.<P> In addition, the highest of the adjusted federal long-term rates for the month of a "change in ownership" under Internal Revenue Code section 382 and the prior two months becomes the <b>federal long-term tax-exempt rate</b> for that month, which in turn determines the annual limitation on the use of corporate net operating loss carryovers following such a change in ownership.<p> The current IRS Revenue Ruling has all the AFRs (and rates derived from the AFRs) but only for the most recently available month (April 2014).<p> <center> <img src="../images/logo48x40.gif" height=40 width=48 alt="Pillsbury Winthrop Shaw Pittman"></center><p></td></tr></table> </body>