Bulletin No. 2021–14

HIGHLIGHTS

OF THIS ISSUE





Bulletin No. 2021–14

April 5, 2021

These synopses are intended only as aids to the reader in

identifying the subject matter covered. They may not be

relied upon as authoritative interpretations.

ADMINISTRATIVE

INCOME TAX

Notice 2021-17, page 984.

Rev. Rul. 2021-7, page 982.

This notice clarifies section IV.E of Notice 2021–12, 2021–6

I.R.B. 828, by providing a more precise citation in the scope

of that provision.

Finding Lists begin on page ii.

Federal rates; adjusted federal rates; adjusted federal longterm rate, and the long-term tax exempt rate. For purposes

of sections 382, 1274, 1288, 7872 and other sections of

the Code, tables set forth the rates for April 2021.

The IRS Mission

Provide America’s taxpayers top-quality service by helping

them understand and meet their tax responsibilities and enforce the law with integrity and fairness to all.

Introduction

The Internal Revenue Bulletin is the authoritative instrument

of the Commissioner of Internal Revenue for announcing official rulings and procedures of the Internal Revenue Service

and for publishing Treasury Decisions, Executive Orders, Tax

Conventions, legislation, court decisions, and other items of

general interest. It is published weekly.

It is the policy of the Service to publish in the Bulletin all substantive rulings necessary to promote a uniform application

of the tax laws, including all rulings that supersede, revoke,

modify, or amend any of those previously published in the

Bulletin. All published rulings apply retroactively unless otherwise indicated. Procedures relating solely to matters of internal management are not published; however, statements of

internal practices and procedures that affect the rights and

duties of taxpayers are published.

Revenue rulings represent the conclusions of the Service

on the application of the law to the pivotal facts stated in

the revenue ruling. In those based on positions taken in rulings to taxpayers or technical advice to Service field offices,

identifying details and information of a confidential nature are

deleted to prevent unwarranted invasions of privacy and to

comply with statutory requirements.

Rulings and procedures reported in the Bulletin do not have the

force and effect of Treasury Department Regulations, but they

may be used as precedents. Unpublished rulings will not be

relied on, used, or cited as precedents by Service personnel in

the disposition of other cases. In applying published rulings and

procedures, the effect of subsequent legislation, regulations,

court decisions, rulings, and procedures must be considered,

and Service personnel and others concerned are cautioned

against reaching the same conclusions in other cases unless

the facts and circumstances are substantially the same.

The Bulletin is divided into four parts as follows:

Part I.—1986 Code.

This part includes rulings and decisions based on provisions

of the Internal Revenue Code of 1986.

Part II.—Treaties and Tax Legislation.

This part is divided into two subparts as follows: Subpart A,

Tax Conventions and Other Related Items, and Subpart B,

Legislation and Related Committee Reports.

Part III.—Administrative, Procedural, and Miscellaneous.

To the extent practicable, pertinent cross references to these

subjects are contained in the other Parts and Subparts. Also

included in this part are Bank Secrecy Act Administrative

Rulings. Bank Secrecy Act Administrative Rulings are issued

by the Department of the Treasury’s Office of the Assistant

Secretary (Enforcement).

Part IV.—Items of General Interest.

This part includes notices of proposed rulemakings, disbarment and suspension lists, and announcements.

The last Bulletin for each month includes a cumulative index

for the matters published during the preceding months. These

monthly indexes are cumulated on a semiannual basis, and are

published in the last Bulletin of each semiannual period.

The contents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate.

April 5, 2021 

Bulletin No. 2021–14

Part I

Section 1274.—

Determination of Issue

Price in the Case of Certain

Debt Instruments Issued for

Property

(Also Sections 42, 280G, 382, 467, 468, 482, 483,

1288, 7520, 7872.)

Rev. Rul. 2021-7

This revenue ruling provides various

prescribed rates for federal income tax

Annual

AFR

110% AFR

120% AFR

130% AFR

0.12%

0.13%

0.14%

0.16%

AFR

110% AFR

120% AFR

130% AFR

150% AFR

175% AFR

0.89%

0.98%

1.07%

1.16%

1.34%

1.57%

AFR

110% AFR

120% AFR

130% AFR

1.98%

2.18%

2.37%

2.58%

Short-term adjusted AFR

Mid-term adjusted AFR

Long-term adjusted AFR

April 5, 2021

purposes for April 2021 (the current

month). Table 1 contains the shortterm, 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 appropri-

ate 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, 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.

REV. RUL. 2021-7 TABLE 1

Applicable Federal Rates (AFR) for April 2021

Period for Compounding

Semiannual

Quarterly

Short-term

0.12%

0.12%

0.13%

0.13%

0.14%

0.14%

0.16%

0.16%

Mid-term

0.89%

0.89%

0.98%

0.98%

1.07%

1.07%

1.16%

1.16%

1.34%

1.34%

1.56%

1.56%

Long-term

1.97%

1.97%

2.17%

2.16%

2.36%

2.35%

2.56%

2.55%

Annual

0.09%

0.68%

1.51%

REV. RUL. 2021-7 TABLE 2

Adjusted AFR for April 2021

Period for Compounding

Semiannual

0.09%

0.68%

1.50%

982

Monthly

0.12%

0.13%

0.14%

0.16%

0.89%

0.98%

1.07%

1.16%

1.34%

1.55%

1.96%

2.16%

2.35%

2.55%

Quarterly

0.09%

0.68%

1.50%

Monthly

0.09%

0.68%

1.50%

Bulletin No. 2021–14

REV. RUL. 2021-7 TABLE 3

Rates Under Section 382 for April 2021

Adjusted federal long-term rate for the current month

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.)

1.51%

1.51%

REV. RUL. 2021-7 TABLE 4

Appropriate Percentages Under Section 42(b)(1) for April 2021

Note: Under section 42(b)(2), the applicable percentage for non-federally subsidized new buildings placed in service after July

30, 2008, shall not be less than 9%.

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

7.33%

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

3.14%

REV. RUL. 2021-7 TABLE 5

Rate Under Section 7520 for April 2021

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

Section 42.—Low-Income

Housing Credit

The applicable federal short-term, mid-term,

and long-term rates are set forth for the month of

April 2021. See Rev. Rul. 2021-7, page 982.

Section 280G.—Golden

Parachute Payments

The applicable federal short-term, mid-term,

and long-term rates are set forth for the month of

April 2021. See Rev. Rul. 2021-7, page 982.

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 April 2021. See Rev.

Rul. 2021-7, page 982.

Section 467.—Certain

Payments for the Use of

Property or Services

The applicable federal short-term, mid-term,

and long-term rates are set forth for the month of

April 2021. See Rev. Rul. 2021-7, page 982.

Section 468.—Special

Rules for Mining and Solid

Waste Reclamation and

Closing Costs

The applicable federal short-term rates are set

forth for the month of April 2021. See Rev. Rul.

2021-7, page 982.

Section 482.—Allocation

of Income and Deductions

Among Taxpayers

The applicable federal short-term, mid-term,

and long-term rates are set forth for the month of

April 2021. See Rev. Rul. 2021-7, page 982.

1.00%

Section 483.—Interest on

Certain Deferred Payments

The applicable federal short-term, mid-term,

and long-term rates are set forth for the month of

April 2021. See Rev. Rul. 2021-7, page 982.

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

April 2021. See Rev. Rul. 2021-7, page 982.

Section 7520.—Valuation

Tables

The applicable federal mid-term rates are set

forth for the month of April 2021. See Rev. Rul.

2021-7, page 982.

Section 7872.—Treatment

of Loans With BelowMarket Interest Rates

The applicable federal short-term, mid-term,

and long-term rates are set forth for the month of

April 2021. See Rev. Rul. 2021-7, page 982.

Bulletin No. 2021–14

983

April 5, 2021

Part III

Notice 2021-17

As clarified, section IV.E now reads:

I. PURPOSE

 . EXTENSION TO SATISFY OCCUE

PANCY OBLIGATIONS

This notice clarifies Notice 2021–12,

2021–6 I.R.B. 828, by providing a more

precise citation in section IV.E of that notice.

II. CLARIFICATION

In section IV.E, id. at 831, “§ 42(f)” is

revised to be “§ 42(f)(3)(A)(ii)”.

April 5, 2021

or purposes of § 42(f)(3)(A)(ii), if

F

the close of the first year of the credit

period with respect to a building is on

or after April 1, 2020, and on or before

June 30, 2021, then the qualified basis

for the building for the first year of the

credit period is calculated by taking

into account any increase in the num-

984

ber of low-income units by the close of

the 6-month period following the close

of that first year.

III. EFFECT ON OTHER

DOCUMENTS

Notice 2021-12 is clarified.

Bulletin No. 2021–14

Definition of Terms

Revenue rulings and revenue procedures

(hereinafter referred to as “rulings”) that

have an effect on previous rulings use the

following defined terms to describe the

­effect:

Amplified describes a situation where

no change is being made in a prior published position, but the prior position is

being extended to apply to a variation of

the fact situation set forth therein. Thus, if

an earlier ruling held that a principle applied to A, and the new ruling holds that

the same principle also applies to B, the

earlier ruling is amplified. (Compare with

modified, below).

Clarified is used in those instances

where the language in a prior ruling is being made clear because the language has

caused, or may cause, some confusion. It

is not used where a position in a prior ruling is being changed.

Distinguished describes a situation

where a ruling mentions a previously published ruling and points out an essential

difference between them.

Modified is used where the substance

of a previously published position is being

changed. Thus, if a prior ruling held that a

principle applied to A but not to B, and the

new ruling holds that it applies to both A

and B, the prior ruling is modified because

it corrects a published position. (Compare

with amplified and clarified, above).

Obsoleted describes a previously published ruling that is not considered determinative with respect to future transactions.

This term is most commonly used in a ruling

that lists previously published rulings that

are obsoleted because of changes in laws or

regulations. A ruling may also be obsoleted

because the substance has been included in

regulations subsequently adopted.

Revoked describes situations where the

position in the previously published ruling

is not correct and the correct position is

being stated in a new ruling.

Superseded describes a situation where

the new ruling does nothing more than

restate the substance and situation of a

previously published ruling (or rulings).

Thus, the term is used to republish under

the 1986 Code and regulations the same

position published under the 1939 Code

and regulations. The term is also used

when it is desired to republish in a single

ruling a series of situations, names, etc.,

that were previously published over a

period of time in separate rulings. If the

new ruling does more than restate the substance of a prior ruling, a combination of

terms is used. For example, modified and

superseded describes a situation where the

substance of a previously published ruling

is being changed in part and is continued

without change in part and it is desired to

restate the valid portion of the previously published ruling in a new ruling that is

self contained. In this case, the previously

published ruling is first modified and then,

as modified, is superseded.

Supplemented is used in situations in

which a list, such as a list of the names of

countries, is published in a ruling and that

list is expanded by adding further names

in subsequent rulings. After the original

ruling has been supplemented several

times, a new ruling may be published that

includes the list in the original ruling and

the additions, and supersedes all prior rulings in the series.

Suspended is used in rare situations to

show that the previous published rulings

will not be applied pending some future

action such as the issuance of new or

amended regulations, the outcome of cases in litigation, or the outcome of a Service study.

Abbreviations

The following abbreviations in current use

and formerly used will appear in material

published in the Bulletin.

A—Individual.

Acq.—Acquiescence.

B—Individual.

BE—Beneficiary.

BK—Bank.

B.T.A.—Board of Tax Appeals.

C—Individual.

C.B.—Cumulative Bulletin.

CFR—Code of Federal Regulations.

CI—City.

COOP—Cooperative.

Ct.D.—Court Decision.

CY—County.

D—Decedent.

DC—Dummy Corporation.

DE—Donee.

Del. Order—Delegation Order.

DISC—Domestic International Sales Corporation.

DR—Donor.

E—Estate.

EE—Employee.

E.O.—Executive Order.

ER—Employer.

Bulletin No. 2021–14

ERISA—Employee Retirement Income Security Act.

EX—Executor.

F—Fiduciary.

FC—Foreign Country.

FICA—Federal Insurance Contributions Act.

FISC—Foreign International Sales Company.

FPH—Foreign Personal Holding Company.

F.R.—Federal Register.

FUTA—Federal Unemployment Tax Act.

FX—Foreign corporation.

G.C.M.—Chief Counsel’s Memorandum.

GE—Grantee.

GP—General Partner.

GR—Grantor.

IC—Insurance Company.

I.R.B.—Internal Revenue Bulletin.

LE—Lessee.

LP—Limited Partner.

LR—Lessor.

M—Minor.

Nonacq.—Nonacquiescence.

O—Organization.

P—Parent Corporation.

PHC—Personal Holding Company.

PO—Possession of the U.S.

PR—Partner.

PRS—Partnership.

i

PTE—Prohibited Transaction Exemption.

Pub. L.—Public Law.

REIT—Real Estate Investment Trust.

Rev. Proc.—Revenue Procedure.

Rev. Rul.—Revenue Ruling.

S—Subsidiary.

S.P.R.—Statement of Procedural Rules.

Stat.—Statutes at Large.

T—Target Corporation.

T.C.—Tax Court.

T.D.—Treasury Decision.

TFE—Transferee.

TFR—Transferor.

T.I.R.—Technical Information Release.

TP—Taxpayer.

TR—Trust.

TT—Trustee.

U.S.C.—United States Code.

X—Corporation.

Y—Corporation.

Z—Corporation.

April 5, 2021

Numerical Finding List1

Bulletin 2021–14

Announcements:

2021-01, 2021-04 I.R.B. 506

2021-02, 2021-08 I.R.B. 892

2021-03, 2021-08 I.R.B. 892

2021-04, 2021-09 I.R.B. 895

2021-05, 2021-13 I.R.B. 965

Notices:

2021-01, 2021-02 I.R.B. 315

2021-03, 2021-02 I.R.B. 316

2021-04, 2021-02 I.R.B. 319

2021-02, 2021-03 I.R.B. 478

2021-05, 2021-03 I.R.B. 479

2021-07, 2021-03 I.R.B. 482

2021-09, 2021-05 I.R.B. 678

2021-06, 2021-06 I.R.B. 822

2021-08, 2021-06 I.R.B. 823

2021-11, 2021-06 I.R.B. 827

2021-12, 2021-06 I.R.B. 828

2021-13, 2021-06 I.R.B. 832

2021-10, 2021-07 I.R.B. 888

2021-15, 2021-10 I.R.B. 898

2021-16, 2021-10 I.R.B. 907

2021-18, 2021-11 I.R.B. 911

2021-19, 2021-11 I.R.B. 920

2021-20, 2021-11 I.R.B. 922

2021-17, 2021-14 I.R.B. 984

Revenue Rulings:—Continued

2021-04, 2021-06 I.R.B. 724

2021-05, 2021-10 I.R.B. 896

2021-06, 2021-12 I.R.B. 946

2021-07, 2021-14 I.R.B. 982

Treasury Decisions:

9925, 2021-02 I.R.B. 296

9940, 2021-02 I.R.B. 311

9932, 2021-03 I.R.B. 345

9939, 2021-03 I.R.B. 376

9941, 2021-03 I.R.B. 396

9942, 2021-03 I.R.B. 450

9937, 2021-04 I.R.B. 495

9936, 2021-05 I.R.B. 508

9943, 2021-05 I.R.B. 577

9945, 2021-05 I.R.B. 627

9946, 2021-06 I.R.B. 726

9947, 2021-06 I.R.B. 748

9948, 2021-06 I.R.B. 801

9938, 2021-07 I.R.B. 838

Proposed Regulations:

REG-130081-19, 2021-02 I.R.B. 321

REG-114615-16, 2021-03 I.R.B. 489

REG-111950-20, 2021-05 I.R.B. 683

REG-115057-20, 2021-05 I.R.B. 714

Revenue Procedures:

2021-01, 2020-01 I.R.B. 1

2021-02, 2020-01 I.R.B. 116

2021-03, 2020-01 I.R.B. 140

2021-04, 2020-01 I.R.B. 157

2021-05, 2020-01 I.R.B. 250

2021-07, 2020-01 I.R.B. 290

2021-09, 2020-03 I.R.B. 485

2021-08, 2020-04 I.R.B. 502

2021-10, 2020-04 I.R.B. 503

2021-12, 2020-05 I.R.B. 681

2021-11, 2020-06 I.R.B. 833

2021-15, 2020-08 I.R.B. 891

Revenue Rulings:

2021-01, 2021-02 I.R.B. 294

2021-02, 2021-04 I.R.B. 495

2021-03, 2021-05 I.R.B. 674

A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2020–27 through 2020–52 is in Internal Revenue Bulletin

2020–52, dated December 27, 2020.

1

April 5, 2021

ii

Bulletin No. 2021–14

Finding List of Current Actions on

Previously Published Items1

Bulletin 2021–14

A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2020–27 through 2020–52 is in Internal Revenue Bulletin

2020–52, dated December 27, 2020.

1

Bulletin No. 2021–14

iii

April 5, 2021

Internal Revenue Service

Washington, DC 20224

Official Business

Penalty for Private Use, $300

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