# Bulletin No. 2021–15

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URL: https://www.frixlaw.com/law-library/documents/agency%3Airs%3A72b9880dea606310

## Record

- **Collection:** Agency decision
- **Document type:** Agency decision

## Text

HIGHLIGHTS
OF THIS ISSUE




Bulletin No. 2021–15
April 12, 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

EMPLOYEE PLANS

Announcement 2021-6, page 1011.

Notice 2021-22, page 987.

This Announcement is issued pursuant to § 521(b) of Pub.
L. 106-170, the Ticket to Work and Work Incentives Improvement Act of 1999, which requires the Secretary of the
Treasury to report annually to the public concerning advance
pricing agreements (APAs) and the Advance Pricing and Mutual Agreement Program (APMA Program), formerly known
as the Advance Pricing Agreement Program (APA Program).
This twenty-second report describes the experience, structure, and activities of the APMA Program during calendar
year 2020.

Notice 2021-21, page 986.

This notice provides additional tax relief under section 7508A
of the Code for taxpayers affected by the Coronavirus Disease (COVID-19) emergency. Specified Federal income tax
filings and payments due on April 15, 2021, are postponed
to May 17, 2021. The filing and furnishing of specified
Forms 5498 are also postponed to June 30, 2021. Claims
for Federal income tax credit or refund that are expiring on
or after April 15, 2021, and before May 17, 2021, are also
postponed to May 17, 2021. This notice also postpones the
application date to participate in the Annual Filing Season
Program.

ADMINISTRATIVE, INCOME TAX
Rev. Proc. 2021-17, page 991.

This revenue procedure provides issuers of qualified mortgage bonds, as defined in § 143(a) of the Internal Revenue
Code (Code), and issuers of mortgage credit certificates, as
defined in § 25(c), with (1) the nationwide average purchase
price for residences located in the United States, and (2) average area purchase price safe harbors for residences located in statistical areas in each state, the District of Columbia,
Puerto Rico, the Northern Mariana Islands, American Samoa,
the Virgin Islands, and Guam.
Finding Lists begin on page ii.

This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for
March 2021 used under § 417(e)(3)(D), the 24-month average segment rates applicable for March 2021, and the
30-year Treasury rates, as reflected by the application of §
430(h)(2)(C)(iv).

INCOME TAX
Action On Decision 2021-1, page 985.

Nonacquiescence to the holding that an interest in a defined
benefit pension plan is not an asset for purposes of applying
the insolvency exclusion in I.R.C. § 108.

Announcement 2021-7, page 1061.

Announcement 2021-7 notifies taxpayers that amounts paid
for personal protective equipment for the primary purpose of
preventing the spread of the Coronavirus Disease 2019 are
amounts treated as paid for medical care under § 213(d) of
the Internal Revenue Code. As a result, these amounts are
qualified medical expenses eligible to be paid or reimbursed
without being included in gross income under health flexible
spending arrangements (health FSAs), Archer medical savings accounts (Archer MSAs), health reimbursement arrangements (HRAs), or health savings accounts (HSAs). In addition,
the announcement notifies administrators of group health
plans regarding the ability to make certain plan amendments
pursuant to the announcement.

Rev. Proc. 2021-18, page 1007.

Revenue Procedure 2021-18 provides an automatic procedure for a State or local government in which an empowerment zone is located to extend the empowerment zone designation made under section 1391(a) of the Internal Revenue
Code (Code). Specifically, this revenue procedure provides
that a State or local government that nominated an empow-

erment zone is deemed to extend until December 31, 2025,
the termination date designated by that State or local government in its empowerment zone nomination (designated
termination date), as described in section 1391(d)(1)(B). This
revenue procedure further provides the procedure for such
State or local government to decline this deemed extension
of its designated termination date.

Rev. Proc. 2021-19, page 1008.

This revenue procedure provides guidance with respect to
the United States and area median gross income figures for
use by issuers of qualified mortgage bonds under § 143(a)
of the Internal Revenue Code and issuers of mortgage credit

certificates under § 25(c) (collectively, “issuers”) in computing the income requirements under § 143(f). This revenue
procedure provides that issuers must use either (1) the income figures the Department of Housing and Urban Development (“HUD”) released most recently or (2) the income
figures HUD released immediately prior to the income figures
HUD released most recently, determined as of the date a
mortgage loan or mortgage credit certificate is committed
to a mortgagor. This revenue procedure also provides a 90day transition period, following the release of the HUD income figures in a current calendar year, for issuers to use
the income figures HUD released during the second calendar
year prior to the current calendar year..

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 12, 2021 

Bulletin No. 2021–15

Actions Relating to Court
Decisions
It is the policy of the Internal Reve­
nue Service to announce at an early date
whether it will follow the holdings in cer­
tain cases. An Action on Decision is the
document making such an announcement.
An Action on Decision will be issued at
the discretion of the Service only on un­
appealed issues decided adverse to the
government. Generally, an Action on De­
cision is issued where its guidance would
be helpful to Service personnel working
with the same or similar issues. Unlike a
Treasury Regulation or a Revenue Ruling,
an Action on Decision is not an affirma­
tive statement of Service position. It is not
intended to serve as public guidance and
may not be cited as precedent.
Actions on Decisions shall be relied
upon within the Service only as conclu­
sions applying the law to the facts in the
particular case at the time the Action on
Decision was issued. Caution should be

1

exercised in extending the recommenda­
tion of the Action on Decision to similar
cases where the facts are different. More­
over, the recommendation in the Action
on Decision may be superseded by new
legislation, regulations, rulings, cases, or
Actions on Decisions.
Prior to 1991, the Service published
acquiescence or nonacquiescence only in
certain regular Tax Court opinions. The
Service has expanded its acquiescence
program to include other civil tax cases
where guidance is determined to be help­
ful. Accordingly, the Service now may
acquiesce or nonacquiesce in the holdings
of memorandum Tax Court opinions, as
well as those of the United States District
Courts, Claims Court, and Circuit Courts
of Appeal. Regardless of the court decid­
ing the case, the recommendation of any
Action on Decision will be published in
the Internal Revenue Bulletin.
The recommendation in every Action
on Decision will be summarized as ac­
quiescence, acquiescence in result only,
or nonacquiescence. Both “acquiescence”

and “acquiescence in result only” mean
that the Service accepts the holding of the
court in a case and that the Service will fol­
low it in disposing of cases with the same
controlling facts. However, “acqui­escence”
indicates neither approval nor disapprov­
al of the reasons assigned by the court for
its conclusions; whereas, “acqui­
escence
in result only” indicates disagree­ment or
concern with some or all of those reasons.
“Nonacquiescence” signifies that, although
no further review was sought, the Service
does not agree with the hold­ing of the court
and, generally, will not follow the decision
in disposing of cases involving other tax­
payers. In reference to an opinion of a cir­
cuit court of appeals, a “nonacquiescence”
indicates that the Ser­vice will not follow
the holding on a na­tionwide basis. Howev­
er, the Service will recognize the preceden­
tial impact of the opinion on cases arising
within the venue of the deciding circuit.
The Commissioner does NOT ACQUI­
ESCE in the following decision:
Schieber v. Commissioner, T.C. Memo.
2017-32, T.C. Docket No. 21690-14.1

Nonacquiescence to the holding that an interest in a defined benefit pension plan is not an asset for purposes of applying the insolvency exclusion in I.R.C. § 108.

Bulletin No. 2021–15

985

April 12, 2021

Part III
RELIEF FOR FORM 1040
FILERS AFFECTED BY
ONGOING CORONAVIRUS
DISEASE 2019 PANDEMIC
Notice 2021-21
I. PURPOSE
On March 13, 2020, the President of
the United States issued an emergency
declaration under the Robert T. Stafford
Disaster Relief and Emergency Assistance
Act in response to the ongoing Coronavi­
rus Disease 2019 (COVID-19) pandemic
(Emergency Declaration). The Emergen­
cy Declaration instructed the Secretary of
the Treasury “to provide relief from tax
deadlines to Americans who have been
adversely affected by the COVID-19
emergency, as appropriate, pursuant to 26
U.S.C. 7508A(a).” Pursuant to the Emer­
gency Declaration, this notice provides
relief under section 7508A of the Internal
Revenue Code (Code) for the persons de­
scribed in section III.A of this notice that
the Secretary of the Treasury has deter­
mined to be affected by the COVID-19
emergency.
II. BACKGROUND
Section 7508A provides the Secretary
of the Treasury or her delegate (Secretary)
with authority to postpone the time for
performing certain acts under the internal
revenue laws for a taxpayer determined by
the Secretary to be affected by a Federal­
ly declared disaster as defined in section
165(i)(5)(A) of the Code. Pursuant to sec­
tion 7508A(a), a period of up to one year
may be disregarded in determining wheth­
er the performance of certain acts is timely
under the internal revenue laws.
III. GRANT OF RELIEF
A. Taxpayers Affected by COVID-19
Emergency
The Secretary has determined that any
person with a Federal income tax return

April 12, 2021

filed on Form 1040, Form 1040-SR, Form
1040-NR, Form 1040-PR, Form 1040-SS,
or Form 1040(SP) (Form 1040 series), or
a Federal income tax payment reported on
one of these forms, that absent this notice
would be due April 15, 2021, is affected
by the COVID-19 emergency for purpos­
es of the relief described in this section III
(Affected Taxpayer). In addition, persons
who are required to file and furnish Form
5498, IRA Contribution Information,
Form 5498-ESA, Coverdell ESA Contri­
bution Information, and Form 5498-SA,
HSA, Archer MSA, or Medicare Advan­
tage MSA Information (Form 5498 series)
that absent this notice would generally be
due June 1, 2021, are Affected Taxpayers.
The Secretary has also determined that
any individual with a period of limitations
to file a claim for credit or refund of Feder­
al income tax that absent this notice would
expire on or after April 15, 2021, and be­
fore May 17, 2021 (for example, certain
individual taxpayers with claims for credit
or refund in respect of their 2017 taxable
years), is an Affected Taxpayer.
B. Postponement of Due Dates with
Respect to Certain Federal Tax
Returns and Federal Tax Payments
For an Affected Taxpayer, the due date
for filing Federal income tax returns in
the Form 1040 series and making Federal
income tax payments in connection with
one of these forms having an original due
date of April 15, 2021, is automatical­
ly postponed to May 17, 2021. Affected
Taxpayers do not have to file any form,
including Form 4868, Application for Au­
tomatic Extension of Time to File U.S.
Individual Income Tax Return, to obtain
this relief. This relief includes the filing of
all schedules, returns, and other forms that
are filed as attachments to the Form 1040
series or are required to be filed by the due
date of the Form 1040 series, including,
for example, Schedule H and Schedule
SE, as well as Forms 965-A, 3520, 5329,
5471, 8621, 8858, 8865, 8915-E, and
8938. Finally, elections that are made or
required to be made on a timely filed Form
1040 series (or attachment to such form)
will be timely made if filed on such form

986

or attachment, as appropriate, on or before
May 17, 2021.
As a result of the postponement of
the due date for Affected Taxpayers to
file Federal income tax returns and make
Federal income tax payments from April
15, 2021, to May 17, 2021, the period be­
ginning on April 15, 2021, and ending on
May 17, 2021, will be disregarded in the
calculation of any interest, penalty, or ad­
dition to tax for failure to file the Federal
income tax returns or to pay the Federal
income taxes postponed by this notice. In­
terest, penalties, and additions to tax with
respect to such postponed Federal income
tax filings and payments will begin to ac­
crue on May 18, 2021.
The postponement of the due date for
filing these Federal income tax returns to
May 17, 2021, also automatically post­
pones to the same date the time for Affect­
ed Taxpayers to make 2020 contributions
to their individual retirement arrangements
(IRAs and Roth IRAs), health savings ac­
counts (HSAs), Archer Medical Savings
Accounts (Archer MSAs), and Coverdell
education savings accounts (Coverdell
ESAs). This postponement also automati­
cally postpones to May 17, 2021, the time
for reporting and payment of the 10-per­
cent additional tax on amounts includible
in gross income from 2020 distributions
from IRAs or workplace-based retirement
plans.
Forms in the Form 5498 series must be
filed with the IRS and furnished to partic­
ipants and beneficiaries by the due date
specified in General Instructions for Cer­
tain Information Returns (Forms 1096,
1097, 1098, 1099, 3921, 3922, 5498, and
W-2G). Because filers of Form 5498 se­
ries are Affected Taxpayers, the due date
for filing and furnishing the Form 5498
series is postponed to June 30, 2021. The
period beginning on the original due date
of those forms and ending on June 30,
2021, will be disregarded in the calcula­
tion of any penalty for failure to file those
forms. Penalties with respect to such a
postponed filing will begin to accrue on
July 1, 2021.
The relief provided in this section III.B
for filing Federal income tax returns and
paying Federal income taxes is available

Bulletin No. 2021–15

solely with respect to the Form 1040 se­
ries returns having an original due date of
April 15, 2021, in respect of an Affected
Taxpayer’s 2020 taxable year, and the
Form 5498 series returns that are due as
described above. Businesses and any other
type of taxpayer who file Federal income
tax returns on forms outside of the Form
1040 series are not Affected Taxpayers for
purposes of the relief described in this sec­
tion III.B.
No extension is provided in this notice
for the payment or deposit of any other
type of Federal tax, including Federal es­
timated income tax payments, or for the
filing of any Federal return other than the
Form 1040 series and the Form 5498 se­
ries for the 2020 taxable year.
C. Relief with Respect to Certain
Claims for Refund
Individuals with a period of limitations
to file a claim for credit or refund of Fed­
eral income tax expiring on or after April
15, 2021, and before May 17, 2021, have
until May 17, 2021, to file those claims
for credit or refund. This postponement is
limited to claims for credit or refund prop­
erly filed on the Form 1040 series or on a
Form 1040-X.
As a result of the postponement of the
time for individuals to file claims for cred­
it or refund of Federal income tax where
the period to file that claim expires on or
after April 15, 2021, and before May 17,
2021, the period beginning on April 15,
2021, and ending on May 17, 2021, will
be disregarded in determining whether the
filing of those claims is timely.
IV. Extension of Time to Participate in
the Annual Filing Season Program
Revenue Procedure 2014-42, 201429 IRB 192, created a voluntary Annual
Filing Season Program to encourage tax
return preparers who do not have creden­
tials as practitioners under Treasury De­
partment Circular No. 230 (Regulations
Governing Practice before the Internal
Revenue Service) to complete continuing

education courses for the purpose of in­
creasing their knowledge of the law rel­
evant to Federal tax returns. Tax return
preparers who complete the requirements
in Rev. Proc. 2014-42 receive an annual
Record of Completion. Under Rev. Proc.
2014-42, applications to participate in the
Annual Filing Season Program for the
2021 calendar year must be received by
April 15, 2021. In light of the relief grant­
ed in section III of this notice, the 2021
calendar year application deadline is post­
poned to May 17, 2021.
V. CONTACT INFORMATION
The principal author of this notice is
Jennifer Auchterlonie of the Office of
Associate Chief Counsel, Procedure and
Administration. For further information
regarding this notice, you may call (202)
317-5436 (not a toll-free number).

Update for Weighted
Average Interest Rates,
Yield Curves, and Segment
Rates
Notice 2021-22
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 aver­
age 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).
This notice does not provide 24-month
average segment rates determined under
§ 430(h)(2)(C)(iv) of the Code reflecting
the modifications made by § 9706(a) of
the American Rescue Plan Act of 2021,
Pub. L. No. 117-2 (ARPA), which was en­

acted on March 11, 2021. Those rates will
be provided in future guidance.
YIELD CURVE AND SEGMENT
RATES
Section 430 specifies the minimum
funding requirements that apply to sin­
gle-employer plans (except for CSEC
plans under § 414(y)) pursuant to § 412.
Section 430(h)(2) specifies the inter­
est rates that must be used to determine
a plan’s target normal cost and funding
target. Under this provision, present val­
ue is generally determined using three
24-month average interest rates (“segment
rates”), each of which applies to cash
flows during specified periods. To the ex­
tent provided under § 430(h)(2)(C)(iv),
these segment rates are adjusted by the ap­
plicable percentage of the 25-year average
segment rates for the period ending Sep­
tember 30 of the year preceding the cal­
endar 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. Con­
sistent with the methodology specified in
Notice 2007-81, the monthly corporate
bond yield curve derived from February
2021 data is in Table 2021-2 at the end
of this notice. The spot first, second, and
third segment rates for the month of Feb­
ruary 2021 are, respectively, 0.51, 2.54,
and 3.45.
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 applica­
ble minimum and maximum percentages
of the corresponding 25-year average seg­
ment rates. The 25-year average segment
rates for plan years beginning in 2020,
and 2021 were published Notice 2019-51,
2019-41 I.R.B. 866, and Notice 2020-72,
2020-40 I.R.B. 789, respectively.

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)).
1

Bulletin No. 2021–15

987

April 12, 2021

24-MONTH AVERAGE CORPORATE
BOND SEGMENT RATES

2021 without adjustment for the 25-year
average segment rate limits are as follows:

24-Month Average Segment Rates Without 25-Year Average Adjustment
First Segment
Second Segment
1.54
2.89

Applicable Month
March 2021

AMERICAN RESCUE PLAN ACT
25-YEAR AVERAGE SEGMENT
RATES
Section 9706(a) of ARPA changes the
25-year average segment rates and the
applicable minimum and maximum per­
centages used under § 430(h)(3)(C)(iv)
of the Code to adjust the 24-month av­
erage segment rates. Prior to this change,
the applicable minimum and maximum
percentages were 90% and 110% for a
plan year beginning in 2020, and 85%
and 115% for a plan year beginning in

For Plan Years
Beginning In

The three 24-month average corporate
bond segment rates applicable for March

2021, respectively. After this change, the
applicable minimum and maximum per­
centages are 95% and 105% for a plan
year beginning in 2020 or 2021. In addi­
tion, pursuant to this change, any 25-year
average segment rate that is less than 5%
is deemed to be 5%.
Pursuant to § 9706(c)(1) of ARPA,
these changes apply with respect to plan
years beginning on or after January 1,
2020. However, § 9706(c)(2) of ARPA
provides that a plan sponsor may elect
not to have these changes apply to any
plan year beginning before January 1,
2022.2

Third Segment
3.55

The rates set forth in this notice do not
reflect the changes to § 430(h)(2)(C)(iv)
of the Code made by § 9706(a) of ARPA.
Accordingly, the adjusted 24-month aver­
age segment rates set forth in this notice
apply only for plan years for which an
election under § 9706(c)(2) of ARPA is
in effect. For a plan year for which such
an election applies, the 24-month aver­
ages applicable for March 2021, adjusted
to be within the applicable minimum and
maximum percentages of the correspond­
ing 25-year average segment rates in ac­
cordance with § 430(h)(2)(C)(iv) of the
Code, are as follows:

Adjusted 24-Month Average Segment Rates
Applicable
First
Second
Month
Segment
Segment

Third
Segment

2020

March 2021

3.64

5.21

5.94

2021

March 2021

3.32

4.79

5.47

Section 431 specifies the minimum
funding requirements that apply to multi­
employer 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
vides that the interest rate used to calcu­
late 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 of interest on 30-year Trea­
sury securities for February 2021 is 2.04
percent. The Service determined this rate
as the average of the daily determinations

For Plan Years
Beginning In

Treasury Weighted Average Rates
30-Year Treasury
Weighted Average

Permissible Range
90% to 105%

March 2021

2.25

2.03 to 2.37

30-YEAR TREASURY SECURITIES
INTEREST RATES

of yield on the 30-year Treasury bond ma­
turing in November 2050 determined each
day through February 10, 2021, and the
yield on the 30-year Treasury bond ma­
turing in February 2051 determined each
day for the balance of the month . For
plan years beginning in March 2021, the
weighted average of the rates of interest
on 30-year Treasury securities and the
permissible range of rates used to calcu­
late current liability are as follows:

This election may be made either for all purposes for which the amendments under § 9706 of ARPA apply or solely for purposes of determining the adjusted funding target attainment
percentage under § 436 of the Code for the plan year.
2

April 12, 2021

988

Bulletin No. 2021–15

MINIMUM PRESENT VALUE
SEGMENT RATES
In general, the applicable interest rates

Month
February 2021

ent value segment rates. Pursuant to that
notice, the minimum present value seg­
ment rates determined for February 2021
are as follows:

Minimum Present Value Segment Rates
First Segment
Second Segment
0.51
2.54

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

Bulletin No. 2021–15

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

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

989

Third Segment
3.45

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).

April 12, 2021

Table 2021-2
Monthly Yield Curve for February 2021
Derived from February 2021 Data
Maturity
0.5
1.0
1.5
2.0
2.5
3.0
3.5
4.0
4.5
5.0
5.5
6.0
6.5
7.0
7.5
8.0
8.5
9.0
9.5
10.0
10.5
11.0
11.5
12.0
12.5
13.0
13.5
14.0
14.5
15.0
15.5
16.0
16.5
17.0
17.5
18.0
18.5
19.0
19.5
20.0

Yield
0.18
0.23
0.28
0.35
0.42
0.51
0.61
0.72
0.85
0.98
1.12
1.26
1.41
1.56
1.70
1.84
1.97
2.09
2.21
2.32
2.42
2.51
2.60
2.67
2.74
2.80
2.86
2.90
2.95
2.99
3.02
3.05
3.08
3.10
3.12
3.14
3.16
3.18
3.19
3.20

April 12, 2021

Maturity
20.5
21.0
21.5
22.0
22.5
23.0
23.5
24.0
24.5
25.0
25.5
26.0
26.5
27.0
27.5
28.0
28.5
29.0
29.5
30.0
30.5
31.0
31.5
32.0
32.5
33.0
33.5
34.0
34.5
35.0
35.5
36.0
36.5
37.0
37.5
38.0
38.5
39.0
39.5
40.0

Yield
3.22
3.23
3.24
3.25
3.26
3.27
3.28
3.29
3.30
3.31
3.31
3.32
3.33
3.34
3.34
3.35
3.36
3.37
3.37
3.38
3.39
3.39
3.40
3.40
3.41
3.42
3.42
3.43
3.43
3.44
3.44
3.45
3.45
3.45
3.46
3.46
3.47
3.47
3.47
3.48

Maturity
40.5
41.0
41.5
42.0
42.5
43.0
43.5
44.0
44.5
45.0
45.5
46.0
46.5
47.0
47.5
48.0
48.5
49.0
49.5
50.0
50.5
51.0
51.5
52.0
52.5
53.0
53.5
54.0
54.5
55.0
55.5
56.0
56.5
57.0
57.5
58.0
58.5
59.0
59.5
60.0

Yield
3.48
3.49
3.49
3.49
3.50
3.50
3.50
3.50
3.51
3.51
3.51
3.52
3.52
3.52
3.52
3.53
3.53
3.53
3.53
3.54
3.54
3.54
3.54
3.55
3.55
3.55
3.55
3.55
3.56
3.56
3.56
3.56
3.56
3.57
3.57
3.57
3.57
3.57
3.57
3.58

990

Maturity
60.5
61.0
61.5
62.0
62.5
63.0
63.5
64.0
64.5
65.0
65.5
66.0
66.5
67.0
67.5
68.0
68.5
69.0
69.5
70.0
70.5
71.0
71.5
72.0
72.5
73.0
73.5
74.0
74.5
75.0
75.5
76.0
76.5
77.0
77.5
78.0
78.5
79.0
79.5
80.0

Yield
3.58
3.58
3.58
3.58
3.58
3.59
3.59
3.59
3.59
3.59
3.59
3.59
3.60
3.60
3.60
3.60
3.60
3.60
3.60
3.60
3.61
3.61
3.61
3.61
3.61
3.61
3.61
3.61
3.61
3.62
3.62
3.62
3.62
3.62
3.62
3.62
3.62
3.62
3.62
3.63

Maturity
80.5
81.0
81.5
82.0
82.5
83.0
83.5
84.0
84.5
85.0
85.5
86.0
86.5
87.0
87.5
88.0
88.5
89.0
89.5
90.0
90.5
91.0
91.5
92.0
92.5
93.0
93.5
94.0
94.5
95.0
95.5
96.0
96.5
97.0
97.5
98.0
98.5
99.0
99.5
100.0

Yield
3.63
3.63
3.63
3.63
3.63
3.63
3.63
3.63
3.63
3.63
3.64
3.64
3.64
3.64
3.64
3.64
3.64
3.64
3.64
3.64
3.64
3.64
3.64
3.65
3.65
3.65
3.65
3.65
3.65
3.65
3.65
3.65
3.65
3.65
3.65
3.65
3.65
3.65
3.65
3.66

Bulletin No. 2021–15

Rev. Proc. 2021-17

gage financing provided by the issue are
used by the close of the first semiannual
period beginning after the date the prepay­
ment (or complete repayment) is received
to redeem bonds that are part of the issue.

SECTION 1. PURPOSE

Average Area Purchase Price

This revenue procedure provides is­
suers of qualified mortgage bonds, as de­
fined in § 143(a) of the Internal Revenue
Code (Code), and issuers of mortgage
credit certificates, as defined in § 25(c),
with (1) the nationwide average purchase
price for residences located in the United
States, and (2) average area purchase price
safe harbors for residences located in sta­
tistical areas in each state, the District of
Columbia, Puerto Rico, the Northern Mar­
iana Islands, American Samoa, the Virgin
Islands, and Guam.

.03 Section 143(e)(1) provides that an
issue of bonds meets the purchase price
requirements of § 143(e) if the acquisi­
tion cost of each residence financed by
the issue does not exceed 90 percent of
the average area purchase price applicable
to such residence. Section 143(e)(5) pro­
vides that, in the case of a targeted area
residence (as defined in § 143(j)), § 143(e)
(1) shall be applied by substituting 110
percent for 90 percent.
.04 Section 143(e)(2) provides that
the term “average area purchase price”
means, with respect to any residence, the
average purchase price of single-family
residences (in the statistical area in which
the residence is located) that were pur­
chased during the most recent 12-month
period for which sufficient statistical in­
formation is available. Under §§ 143(e)(3)
and (4), respectively, separate determina­
tions of average area purchase price are to
be made for new and existing residences,
and for two-, three-, and four-family res­
idences.
.05 Section 143(e)(2) also provides that
the determination of the average area pur­
chase price shall be made as of the date
on which the commitment to provide the
financing is made or, if earlier, the date of
the purchase of the residence.
.06 Section 143(k)(2)(A) provides that
the term “statistical area” means (i) a met­
ropolitan statistical area (MSA), and (ii)
any county (or the portion thereof) that is
not within an MSA. Section 143(k)(2)(C)
further provides that if sufficient recent
statistical information with respect to a
county (or portion thereof) is unavailable,
the Secretary may substitute another area
for which there is sufficient recent statis­
tical information for such county (or por­
tion thereof). In the case of any portion
of a State which is not within a county, §
143(k)(2)(D) provides that the Secretary
may designate an area that is the equiva­
lent of a county. Section 6a.103A-1(b)(4)
(i) of the Income Tax Regulations (issued
under § 103A of the Internal Revenue

26 CFR 601.601: Rules and Regulations
(Also Part 1, §§ 25, 143, 6a.103A-1(b)(4),
6a.103A-2(f)(5)).

SECTION 2. BACKGROUND
.01 Section 103(a) provides that, ex­
cept as provided in § 103(b), gross income
does not include interest on any State or
local bond. Section 103(b)(1) provides
that § 103(a) shall not apply to any pri­
vate activity bond that is not a “quali­
fied bond” within the meaning of § 141.
Section 141(e) provides, in part, that the
term “qualified bond” means any private
activity bond if such bond (1) is a quali­
fied mortgage bond under § 143, (2) meets
the volume cap requirements under § 146,
and (3) meets the applicable requirements
under § 147.
.02 Section 143(a)(1) provides that the
term “qualified mortgage bond” means a
bond that is issued as part of a qualified
mortgage issue. Section 143(a)(2)(A) pro­
vides that the term “qualified mortgage is­
sue” means an issue of one or more bonds
by a State or political subdivision thereof,
but only if: (i) all proceeds of the issue
(exclusive of issuance costs and a reason­
ably required reserve) are to be used to fi­
nance owner-occupied residences; (ii) the
issue meets the requirements of subsec­
tions (c), (d), (e), (f), (g), (h), (i), and (m)
(7) of § 143; (iii) the issue does not meet
the private business tests of paragraphs (1)
and (2) of § 141(b); and (iv) with respect
to amounts received more than 10 years
after the date of issuance, repayments of
$250,000 or more of principal on mort­

Bulletin No. 2021–15

991

Code of 1954, the predecessor of § 143 of
the Code) provides that the term “State”
includes a possession of the United States
and the District of Columbia.
.07 Section 6a.103A-2(f)(5)(i) pro­
vides that an issuer may rely upon the
average area purchase price safe harbors
published by the Department of the Trea­
sury (Treasury Department) for the statis­
tical area in which a residence is located.
Section 6a.103A-2(f)(5)(i) further pro­
vides that an issuer may use an average
area purchase price limitation different
from the published safe harbor if the issu­
er has more accurate and comprehensive
data for the statistical area.
Qualified Mortgage Credit Certificate
Program
.08 Section 25(c) permits a State or
political subdivision thereof to establish
a qualified mortgage credit certificate
program. In general, a qualified mortgage
credit certificate program is a program
under which the issuing authority elects
not to issue an amount of private activity
bonds that it may otherwise issue during
the calendar year under § 146, and in its
place, issues mortgage credit certificates
to taxpayers in connection with the acqui­
sition of their principal residences. Sec­
tion 25(a)(1) provides, in general, that the
holder of a mortgage credit certificate may
claim a federal income tax credit equal to
the product of the credit rate specified in
the certificate and the interest paid or ac­
crued during the tax year on the remaining
principal of the indebtedness incurred to
acquire the residence. Section 25(c)(2)(A)
(iii)(III) generally provides that residenc­
es acquired in connection with the issu­
ance of mortgage credit certificates must
meet the purchase price requirements of §
143(e).
Income Limitations for Qualified
Mortgage Bonds and Mortgage Credit
Certificates
.09 Section 143(f) imposes limitations
on the income of mortgagors for whom
financing may be provided by qualified
mortgage bonds. In addition, § 25(c)(2)(A)
(iii)(IV) provides that holders of mortgage
credit certificates must meet the income
requirement of § 143(f). Generally, under

April 12, 2021

§§ 143(f)(1) and 25(c)(2)(A)(iii)(IV), the
income requirement is met only if all own­
er-financing under a qualified mortgage
bond and all mortgage credit certificates
issued under a qualified mortgage credit
certificate program are provided to mort­
gagors whose family income is 115 percent
or less of the applicable median family in­
come. Section 143(f)(5), however, general­
ly provides for an upward adjustment to the
percentage limitation in high housing cost
areas. High housing cost areas are defined
in § 143(f)(5)(C) as any statistical area for
which the housing cost/income ratio is
greater than 1.2.
.10 Under § 143(f)(5)(D), the hous­
ing cost/income ratio with respect to any
statistical area is determined by dividing
(a) the applicable housing price ratio for
such area by (b) the ratio that the area me­
dian gross income for such area bears to
the median gross income for the United
States. The applicable housing price ratio
is the new housing price ratio (new hous­
ing average area purchase price divided
by the new housing average purchase
price for the United States) or the existing
housing price ratio (existing housing av­
erage area purchase price divided by the
existing housing average purchase price
for the United States), whichever results
in the housing cost/income ratio being
closer to 1.
Average Area and Nationwide Purchase
Price Limitations
.11 Average area purchase price safe
harbors for each state, the District of Co­
lumbia, Puerto Rico, the Northern Mari­
ana Islands, American Samoa, the Virgin
Islands, and Guam were last published in
Rev. Proc. 2020-18, I.R.B. 2020-15, 592.
.12 The nationwide average purchase
price limitation was last published in sec­
tion 4.02 of Rev. Proc. 2020-18. Guidance
with respect to the United States and area
median gross income figures that are used
in computing the housing cost/income ra­
tio described in § 143(f)(5) was published
in Rev. Proc. 2021-19, I.R.B. 2021-15 (re­
leased on March 25, 2021).
.13 This revenue procedure uses Fed­
eral Housing Administration (FHA) loan
limits for a given statistical area to calcu­
late the average area purchase price safe
harbor for that area. FHA sets limits on the

April 12, 2021

dollar value of loans it will insure based on
median home prices and conforming loan
limits established by the Federal Home
Loan Mortgage Corporation. In particular,
FHA sets an area’s loan limit at 95 per­
cent of the median home sales price for
the area, subject to certain floors and caps
measured against conforming loan limits.
.14 To calculate the average area pur­
chase price safe harbors in this revenue
procedure, the FHA loan limits are ad­
justed to take into account the differenc­
es between average and median purchase
prices. Because FHA loan limits do not
differentiate between new and existing
residences, this revenue procedure con­
tains a single average area purchase price
safe harbor for both new and existing res­
idences in a statistical area. The Treasury
Department and the Internal Revenue Ser­
vice (IRS) have determined that FHA loan
limits provide a reasonable basis for deter­
mining average area purchase price safe
harbors. If the Treasury Department and
the IRS become aware of other sources
of average purchase price data, including
data that differentiate between new and
existing residences, consideration will be
given as to whether such data provide a
more accurate method for calculating av­
erage area purchase price safe harbors.
.15 The average area purchase price
safe harbors listed in section 4.01 of this
revenue procedure are based on FHA loan
limits released December 2, 2020. FHA
loan limits are available for statistical ar­
eas in each state, the District of Columbia,
Puerto Rico, the Northern Mariana Islands,
American Samoa, the Virgin Islands, and
Guam. See section 3.03 of this revenue
procedure with respect to FHA loan limits
revised after December 2, 2020.
.16 OMB Bulletin No. 03-04, dated
and effective June 6, 2003, revised the
definitions of the nation’s metropolitan
areas and recognized 49 new metropoli­
tan statistical areas. The OMB bulletin no
longer includes primary metropolitan sta­
tistical areas.
SECTION 3. APPLICATION
Average Area Purchase Price Safe
Harbors
.01 Average area purchase price safe
harbors for statistical areas in each state,

992

the District of Columbia, Puerto Rico,
the Northern Mariana Islands, American
Samoa, the Virgin Islands, and Guam are
set forth in section 4.01 of this revenue
procedure. Average area purchase price
safe harbors are provided for single-fam­
ily and two to four-family residences.
For each type of residence, section 4.01
of this revenue procedure contains a sin­
gle safe harbor that may be used for both
new and existing residences. Issuers of
qualified mortgage bonds and issuers of
mortgage credit certificates may rely on
these safe harbors to satisfy the require­
ments of §§ 143(e) and (f). Section 4.01
of this revenue procedure provides safe
harbors for MSAs and for certain coun­
ties and county equivalents. If no pur­
chase price safe harbor is available for a
statistical area, the safe harbor for “ALL
OTHER AREAS” may be used for that
statistical area.
.02 If a residence is in an MSA, the
safe harbor applicable to it is the limita­
tion of that MSA. If an MSA falls in more
than one state, the MSA is listed in sec­
tion 4.01 of this revenue procedure under
each state.
.03 If the FHA revises the FHA loan
limit for any statistical area after Decem­
ber 2, 2020, an issuer of qualified mort­
gage bonds or mortgage credit certificates
may use the revised FHA loan limit for
that statistical area to compute (as provid­
ed in the next sentence) a revised average
area purchase price safe harbor for the sta­
tistical area provided that the issuer main­
tains records evidencing the revised FHA
loan limit. The revised average area pur­
chase price safe harbor for that statistical
area is computed by dividing the revised
FHA loan limit by 1.03.
.04 If, pursuant to § 6a.103A-2(f)
(5)(i), an issuer uses more accurate and
comprehensive data to determine the av­
erage area purchase price for a statistical
area, the issuer must make separate av­
erage area purchase price determinations
for new and existing residences. More­
over, when computing the average area
purchase price for a statistical area that
is an MSA, as defined in OMB Bulletin
No. 03-04, the issuer must make the com­
putation for the entire applicable MSA.
When computing the average area pur­
chase price for a statistical area that is not
an MSA, the issuer must make the com­

Bulletin No. 2021–15

putation for the entire statistical area and
may not combine statistical areas. Thus,
for example, the issuer may not combine
two or more counties.
.05 If an issuer receives a ruling per­
mitting it to rely on an average area pur­
chase price limitation that is higher than
the applicable safe harbor in this revenue
procedure, the issuer may rely on that
higher limitation for the purpose of satis­
fying the requirements of §§ 143(e) and
(f) for bonds sold, and mortgage cred­
it certificates issued, not more than 30
months following the termination date of
the 12-month period used by the issuer to
compute the limitation.
Nationwide Average Purchase Price
.06 Section 4.02 of this revenue pro­
cedure sets forth a single nationwide
average purchase price for purposes of

computing the housing cost/income ratio
under § 143(f)(5).
.07 Issuers must use the nationwide
average purchase price set forth in section
4.02 of this revenue procedure when com­
puting the housing cost/income ratio un­
der § 143(f)(5) regardless of whether they
are relying on the average area purchase
price safe harbors contained in this reve­
nue procedure or using more accurate and
comprehensive data to determine average
area purchase prices for new and existing
residences for a statistical area that are dif­
ferent from the published safe harbors in
this revenue procedure.
.08 If, pursuant to section 6.02 of this
revenue procedure, an issuer relies on the
average area purchase price safe harbors
contained in Rev. Proc. 2020-18, the issuer
must use the nationwide average purchase
price set forth in section 4.02 of Rev. Proc.
2020-18 in computing the housing cost/

income ratio under § 143(f)(5). Likewise,
if, pursuant to section 6.04 of this revenue
procedure, an issuer relies on the nation­
wide average purchase price published in
Rev. Proc. 2020-18, the issuer must use
the average area purchase price safe har­
bors set forth in section 4.01 of Rev. Proc.
2020-18 in computing the housing cost/
income ratio under § 143(f)(5).
SECTION 4. AVERAGE AREA AND
NATIONWIDE AVERAGE PURCHASE
PRICES
.01 Average area purchase prices for
single-family and two to four-family resi­
dences in MSAs, and for certain counties
and county equivalents are set forth be­
low. The safe harbor for “ALL OTHER
AREAS” (found at the end of the table
below) may be used for a statistical area
that is not listed below.

2021 Average Area Purchase Prices for Mortgage Revenue Bonds

County Name
ALEUTIANS WEST
ANCHORAGE MUNIC
JUNEAU CITY AND
KETCHIKAN GATEW
KODIAK ISLAND B
MATANUSKA-SUSIT
NOME CENSUS ARE
SITKA CITY AND
SKAGWAY MUNICIP
YAKUTAT CITY AN

State
AK
AK
AK
AK
AK
AK
AK
AK
AK
AK

One-Unit
Limit
$530,235
$406,066
$469,828
$395,998
$406,066
$406,066
$428,438
$473,184
$403,828
$409,422

Two-Unit
Limit
$678,770
$519,826
$601,438
$506,938
$519,826
$519,826
$548,473
$605,767
$516,957
$524,106

Three-Unit
Limit
$820,497
$628,334
$727,018
$612,771
$628,334
$628,334
$662,963
$732,222
$624,881
$633,538

Four-Unit
Limit
$1,019,712
$780,907
$903,519
$761,550
$780,907
$780,907
$823,901
$909,988
$776,578
$787,375

COCONINO
MARICOPA
PINAL

AZ
AZ
AZ

$379,218
$357,964
$357,964

$485,440
$458,253
$458,253

$586,799
$553,921
$553,921

$729,255
$688,400
$688,400

ALAMEDA
ALPINE
AMADOR
CALAVERAS
CONTRA COSTA
EL DORADO
HUMBOLDT
INYO

CA
CA
CA
CA
CA
CA
CA
CA

$799,948
$450,811
$354,608
$363,557
$799,948
$581,692
$346,778
$363,557

$1,024,284
$577,120
$453,973
$465,402
$1,024,284
$744,673
$443,905
$465,402

$1,238,041
$697,593
$548,716
$562,578
$1,238,041
$900,115
$536,606
$562,578

$1,538,614
$866,945
$681,932
$699,149
$1,538,614
$1,118,638
$666,854
$699,149

Bulletin No. 2021–15

993

April 12, 2021

County Name
LOS ANGELES
MARIN
MENDOCINO
MONO
MONTEREY
NAPA
NEVADA
ORANGE
PLACER
RIVERSIDE
SACRAMENTO
SAN BENITO
SAN BERNARDINO
SAN DIEGO
SAN FRANCISCO
SAN JOAQUIN
SAN LUIS OBISPO
SAN MATEO
SANTA BARBARA
SANTA CLARA
SANTA CRUZ
SOLANO
SONOMA
STANISLAUS
SUTTER
VENTURA
YOLO
YUBA

State
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA

One-Unit
Limit
$799,948
$799,948
$430,676
$514,574
$719,284
$794,233
$512,336
$799,948
$581,692
$464,235
$581,692
$799,948
$464,235
$732,708
$799,948
$469,828
$682,369
$799,948
$642,098
$799,948
$799,948
$535,828
$687,963
$385,930
$363,557
$719,284
$581,692
$363,557

Two-Unit
Limit
$1,024,284
$1,024,284
$551,343
$658,732
$920,834
$1,016,745
$655,863
$1,024,284
$744,673
$594,289
$744,673
$1,024,284
$594,289
$938,003
$1,024,284
$601,438
$873,559
$1,024,284
$822,005
$1,024,284
$1,024,284
$685,968
$880,709
$494,049
$465,402
$920,834
$744,673
$465,402

Three-Unit
Limit
$1,238,041
$1,238,041
$666,417
$796,276
$1,113,045
$1,229,043
$792,823
$1,238,041
$900,115
$718,360
$900,115
$1,238,041
$718,360
$1,133,813
$1,238,041
$727,018
$1,055,946
$1,238,041
$993,594
$1,238,041
$1,238,041
$829,154
$1,064,603
$597,207
$562,578
$1,113,045
$900,115
$562,578

Four-Unit
Limit
$1,538,614
$1,538,614
$828,230
$989,557
$1,383,269
$1,527,379
$985,277
$1,538,614
$1,118,638
$892,771
$1,118,638
$1,538,614
$892,771
$1,409,095
$1,538,614
$903,519
$1,312,260
$1,538,614
$1,234,831
$1,538,614
$1,538,614
$1,030,460
$1,323,009
$742,192
$699,149
$1,383,269
$1,118,638
$699,149

ADAMS
ARAPAHOE
BOULDER
BROOMFIELD
CHAFFEE
CLEAR CREEK
DENVER
DOUGLAS
EAGLE
EL PASO
ELBERT
GARFIELD
GILPIN
GRAND

CO
CO
CO
CO
CO
CO
CO
CO
CO
CO
CO
CO
CO
CO

$580,573
$580,573
$636,505
$580,573
$380,337
$580,573
$580,573
$580,573
$799,826
$382,574
$580,573
$799,948
$580,573
$514,574

$743,214
$743,214
$814,855
$743,214
$486,900
$743,214
$743,214
$743,214
$1,023,943
$489,769
$743,214
$1,024,284
$743,214
$658,732

$898,413
$898,413
$984,937
$898,413
$588,550
$898,413
$898,413
$898,413
$1,237,700
$592,003
$898,413
$1,238,041
$898,413
$796,276

$1,116,498
$1,116,498
$1,224,082
$1,116,498
$731,395
$1,116,498
$1,116,498
$1,116,498
$1,538,176
$735,724
$1,116,498
$1,538,614
$1,116,498
$989,557

April 12, 2021

994

Bulletin No. 2021–15

County Name
GUNNISON
HINSDALE
JEFFERSON
LA PLATA
LARIMER
MONTROSE
OURAY
PARK
PITKIN
ROUTT
SAN MIGUEL
SUMMIT
TELLER
WELD

State
CO
CO
CO
CO
CO
CO
CO
CO
CO
CO
CO
CO
CO
CO

One-Unit
Limit
$397,117
$416,133
$580,573
$436,269
$451,930
$413,896
$413,896
$580,573
$799,948
$659,997
$799,948
$799,948
$382,574
$417,252

Two-Unit
Limit
$508,348
$532,715
$743,214
$558,492
$578,531
$529,845
$529,845
$743,214
$1,024,284
$844,912
$1,024,284
$1,024,284
$489,769
$534,125

Three-Unit
Limit
$614,522
$643,947
$898,413
$675,074
$699,344
$640,493
$640,493
$898,413
$1,238,041
$1,021,317
$1,238,041
$1,238,041
$592,003
$645,649

Four-Unit
Limit
$763,690
$800,264
$1,116,498
$838,979
$869,085
$795,936
$795,936
$1,116,498
$1,538,614
$1,269,265
$1,538,614
$1,538,614
$735,724
$802,404

FAIRFIELD
LITCHFIELD
WINDHAM

CT
CT
CT

$585,048
$347,897
$354,608

$748,953
$445,364
$453,973

$905,319
$538,357
$548,716

$1,125,107
$669,043
$681,932

DISTRICT OF COL

DC

$799,948

$1,024,284

$1,238,041

$1,538,614

NEW CASTLE

DE

$419,489

$536,995

$649,151

$806,733

BAKER
BROWARD
CLAY
COLLIER
DUVAL
MARTIN
MIAMI-DADE
MONROE
NASSAU
OKALOOSA
PALM BEACH
ST. JOHNS
ST. LUCIE
WALTON

FL
FL
FL
FL
FL
FL
FL
FL
FL
FL
FL
FL
FL
FL

$378,100
$391,523
$378,100
$447,455
$378,100
$371,388
$391,523
$591,760
$378,100
$429,557
$391,523
$378,100
$371,388
$429,557

$484,030
$501,199
$484,030
$572,791
$484,030
$475,421
$501,199
$757,561
$484,030
$549,884
$501,199
$484,030
$475,421
$549,884

$585,096
$605,864
$585,096
$692,389
$585,096
$574,688
$605,864
$915,727
$585,096
$664,714
$605,864
$585,096
$574,688
$664,714

$727,115
$752,941
$727,115
$860,476
$727,115
$714,226
$752,941
$1,137,996
$727,115
$826,090
$752,941
$727,115
$714,226
$826,090

BARROW
BARTOW
BUTTS
CARROLL
CHEROKEE

GA
GA
GA
GA
GA

$401,591
$401,591
$401,591
$401,591
$401,591

$514,087
$514,087
$514,087
$514,087
$514,087

$621,428
$621,428
$621,428
$621,428
$621,428

$772,298
$772,298
$772,298
$772,298
$772,298

Bulletin No. 2021–15

995

April 12, 2021

County Name
CLARKE
CLAYTON
COBB
COWETA
DAWSON
DEKALB
DOUGLAS
FAYETTE
FORSYTH
FULTON
GREENE
GWINNETT
HARALSON
HEARD
HENRY
JASPER
LAMAR
MADISON
MERIWETHER
MORGAN
NEWTON
OCONEE
OGLETHORPE
PAULDING
PICKENS
PIKE
ROCKDALE
SPALDING
WALTON

State
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA

One-Unit
Limit
$380,337
$401,591
$401,591
$401,591
$401,591
$401,591
$401,591
$401,591
$401,591
$401,591
$501,150
$401,591
$401,591
$401,591
$401,591
$401,591
$401,591
$380,337
$401,591
$401,591
$401,591
$380,337
$380,337
$401,591
$401,591
$401,591
$401,591
$401,591
$401,591

Two-Unit
Limit
$486,900
$514,087
$514,087
$514,087
$514,087
$514,087
$514,087
$514,087
$514,087
$514,087
$641,563
$514,087
$514,087
$514,087
$514,087
$514,087
$514,087
$486,900
$514,087
$514,087
$514,087
$486,900
$486,900
$514,087
$514,087
$514,087
$514,087
$514,087
$514,087

Three-Unit
Limit
$588,550
$621,428
$621,428
$621,428
$621,428
$621,428
$621,428
$621,428
$621,428
$621,428
$775,508
$621,428
$621,428
$621,428
$621,428
$621,428
$621,428
$588,550
$621,428
$621,428
$621,428
$588,550
$588,550
$621,428
$621,428
$621,428
$621,428
$621,428
$621,428

Four-Unit
Limit
$731,395
$772,298
$772,298
$772,298
$772,298
$772,298
$772,298
$772,298
$772,298
$772,298
$963,780
$772,298
$772,298
$772,298
$772,298
$772,298
$772,298
$731,395
$772,298
$772,298
$772,298
$731,395
$731,395
$772,298
$772,298
$772,298
$772,298
$772,298
$772,298

HAWAII
HONOLULU
KALAWAO
KAUAI
MAUI

HI
HI
HI
HI
HI

$397,117
$701,386
$703,624
$700,268
$703,624

$508,348
$897,878
$900,747
$896,467
$900,747

$614,522
$1,085,371
$1,088,824
$1,083,620
$1,088,824

$763,690
$1,348,835
$1,353,163
$1,346,695
$1,353,163

ADA
BLAINE
BOISE
CAMAS
CANYON
GEM
KOOTENAI

ID
ID
ID
ID
ID
ID
ID

$403,828
$628,675
$403,828
$628,675
$403,828
$403,828
$378,100

$516,957
$804,836
$516,957
$804,836
$516,957
$516,957
$484,030

$624,881
$972,826
$624,881
$972,826
$624,881
$624,881
$585,096

$776,578
$1,209,005
$776,578
$1,209,005
$776,578
$776,578
$727,115

April 12, 2021

996

Bulletin No. 2021–15

County Name
OWYHEE
TETON
VALLEY

State
ID
ID
ID

One-Unit
Limit
$403,828
$799,948
$369,151

Two-Unit
Limit
$516,957
$1,024,284
$472,552

Three-Unit
Limit
$624,881
$1,238,041
$571,235

Four-Unit
Limit
$776,578
$1,538,614
$709,898

COOK
DEKALB
DUPAGE
GRUNDY
KANE
KENDALL
LAKE
MCHENRY
WILL

IL
IL
IL
IL
IL
IL
IL
IL
IL

$369,151
$369,151
$369,151
$369,151
$369,151
$369,151
$369,151
$369,151
$369,151

$472,552
$472,552
$472,552
$472,552
$472,552
$472,552
$472,552
$472,552
$472,552

$571,235
$571,235
$571,235
$571,235
$571,235
$571,235
$571,235
$571,235
$571,235

$709,898
$709,898
$709,898
$709,898
$709,898
$709,898
$709,898
$709,898
$709,898

BOONE
BROWN
HAMILTON
HANCOCK
HENDRICKS
JASPER
JOHNSON
LAKE
MADISON
MARION
MORGAN
NEWTON
PORTER
PUTNAM
SHELBY

IN
IN
IN
IN
IN
IN
IN
IN
IN
IN
IN
IN
IN
IN
IN

$369,151
$369,151
$369,151
$369,151
$369,151
$369,151
$369,151
$369,151
$369,151
$369,151
$369,151
$369,151
$369,151
$369,151
$369,151

$472,552
$472,552
$472,552
$472,552
$472,552
$472,552
$472,552
$472,552
$472,552
$472,552
$472,552
$472,552
$472,552
$472,552
$472,552

$571,235
$571,235
$571,235
$571,235
$571,235
$571,235
$571,235
$571,235
$571,235
$571,235
$571,235
$571,235
$571,235
$571,235
$571,235

$709,898
$709,898
$709,898
$709,898
$709,898
$709,898
$709,898
$709,898
$709,898
$709,898
$709,898
$709,898
$709,898
$709,898
$709,898

JOHNSON
LEAVENWORTH
LINN
MIAMI
WYANDOTTE

KS
KS
KS
KS
KS

$379,218
$379,218
$379,218
$379,218
$379,218

$485,440
$485,440
$485,440
$485,440
$485,440

$586,799
$586,799
$586,799
$586,799
$586,799

$729,255
$729,255
$729,255
$729,255
$729,255

BARNSTABLE
BRISTOL
DUKES
ESSEX
MIDDLESEX
NANTUCKET
NORFOLK

MA
MA
MA
MA
MA
MA
MA

$492,201
$492,201
$799,948
$704,742
$704,742
$799,948
$704,742

$630,085
$630,085
$1,024,284
$902,206
$902,206
$1,024,284
$902,206

$761,647
$761,647
$1,238,041
$1,090,575
$1,090,575
$1,238,041
$1,090,575

$946,563
$946,563
$1,538,614
$1,355,303
$1,355,303
$1,538,614
$1,355,303

Bulletin No. 2021–15

997

April 12, 2021

County Name
PLYMOUTH
SUFFOLK
WORCESTER

State
MA
MA
MA

One-Unit
Limit
$704,742
$704,742
$354,608

Two-Unit
Limit
$902,206
$902,206
$453,973

Three-Unit
Limit
$1,090,575
$1,090,575
$548,716

Four-Unit
Limit
$1,355,303
$1,355,303
$681,932

ANNE ARUNDEL
BALTIMORE
BALTIMORE CITY
CALVERT
CARROLL
CECIL
CHARLES
FREDERICK
HARFORD
HOWARD
MONTGOMERY
PRINCE GEORGE’S
QUEEN ANNE’S
TALBOT

MD
MD
MD
MD
MD
MD
MD
MD
MD
MD
MD
MD
MD
MD

$523,523
$523,523
$523,523
$799,948
$523,523
$419,489
$799,948
$799,948
$523,523
$523,523
$799,948
$799,948
$523,523
$397,117

$670,210
$670,210
$670,210
$1,024,284
$670,210
$536,995
$1,024,284
$1,024,284
$670,210
$670,210
$1,024,284
$1,024,284
$670,210
$508,348

$810,137
$810,137
$810,137
$1,238,041
$810,137
$649,151
$1,238,041
$1,238,041
$810,137
$810,137
$1,238,041
$1,238,041
$810,137
$614,522

$1,006,775
$1,006,775
$1,006,775
$1,538,614
$1,006,775
$806,733
$1,538,614
$1,538,614
$1,006,775
$1,006,775
$1,538,614
$1,538,614
$1,006,775
$763,690

CUMBERLAND
SAGADAHOC
YORK

ME
ME
ME

$392,642
$392,642
$392,642

$502,658
$502,658
$502,658

$607,567
$607,567
$607,567

$755,081
$755,081
$755,081

ANOKA
CARVER
CHISAGO
DAKOTA
HENNEPIN
ISANTI
LE SUEUR
MILLE LACS
RAMSEY
SCOTT
SHERBURNE
WASHINGTON
WRIGHT

MN
MN
MN
MN
MN
MN
MN
MN
MN
MN
MN
MN
MN

$391,523
$391,523
$391,523
$391,523
$391,523
$391,523
$391,523
$391,523
$391,523
$391,523
$391,523
$391,523
$391,523

$501,199
$501,199
$501,199
$501,199
$501,199
$501,199
$501,199
$501,199
$501,199
$501,199
$501,199
$501,199
$501,199

$605,864
$605,864
$605,864
$605,864
$605,864
$605,864
$605,864
$605,864
$605,864
$605,864
$605,864
$605,864
$605,864

$752,941
$752,941
$752,941
$752,941
$752,941
$752,941
$752,941
$752,941
$752,941
$752,941
$752,941
$752,941
$752,941

BATES
CALDWELL
CASS
CLAY
CLINTON
JACKSON

MO
MO
MO
MO
MO
MO

$379,218
$379,218
$379,218
$379,218
$379,218
$379,218

$485,440
$485,440
$485,440
$485,440
$485,440
$485,440

$586,799
$586,799
$586,799
$586,799
$586,799
$586,799

$729,255
$729,255
$729,255
$729,255
$729,255
$729,255

April 12, 2021

998

Bulletin No. 2021–15

County Name
LAFAYETTE
PLATTE
RAY

State
MO
MO
MO

One-Unit
Limit
$379,218
$379,218
$379,218

Two-Unit
Limit
$485,440
$485,440
$485,440

Three-Unit
Limit
$586,799
$586,799
$586,799

Four-Unit
Limit
$729,255
$729,255
$729,255

FLATHEAD
GALLATIN
MISSOULA
PARK
RICHLAND

MT
MT
MT
MT
MT

$368,032
$465,354
$378,100
$366,913
$346,778

$471,141
$595,748
$484,030
$469,682
$443,905

$569,484
$720,111
$585,096
$567,782
$536,606

$707,758
$894,911
$727,115
$705,618
$666,854

CAMDEN
CHATHAM
CURRITUCK
DARE
DURHAM
FRANKLIN
GATES
GRANVILLE
HYDE
JOHNSTON
ORANGE
PASQUOTANK
PERQUIMANS
PERSON
WAKE

NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC

$446,337
$425,083
$446,337
$385,930
$425,083
$361,320
$446,337
$425,083
$469,828
$361,320
$425,083
$783,047
$783,047
$425,083
$361,320

$571,381
$544,193
$571,381
$494,049
$544,193
$462,533
$571,381
$544,193
$601,438
$462,533
$544,193
$1,002,446
$1,002,446
$544,193
$462,533

$690,686
$657,759
$690,686
$597,207
$657,759
$559,125
$690,686
$657,759
$727,018
$559,125
$657,759
$1,211,729
$1,211,729
$657,759
$559,125

$858,336
$817,481
$858,336
$742,192
$817,481
$694,869
$858,336
$817,481
$903,519
$694,869
$817,481
$1,505,882
$1,505,882
$817,481
$694,869

LINCOLN
LOGAN
MCPHERSON

NE
NE
NE

$421,727
$421,727
$421,727

$539,865
$539,865
$539,865

$652,604
$652,604
$652,604

$811,013
$811,013
$811,013

HILLSBOROUGH
ROCKINGHAM
STRAFFORD

NH
NH
NH

$363,557
$704,742
$704,742

$465,402
$902,206
$902,206

$562,578
$1,090,575
$1,090,575

$699,149
$1,355,303
$1,355,303

BERGEN
BURLINGTON
CAMDEN
CAPE MAY
ESSEX
GLOUCESTER
HUDSON
HUNTERDON
MIDDLESEX

NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ

$799,948
$419,489
$419,489
$419,489
$799,948
$419,489
$799,948
$799,948
$799,948

$1,024,284
$536,995
$536,995
$536,995
$1,024,284
$536,995
$1,024,284
$1,024,284
$1,024,284

$1,238,041
$649,151
$649,151
$649,151
$1,238,041
$649,151
$1,238,041
$1,238,041
$1,238,041

$1,538,614
$806,733
$806,733
$806,733
$1,538,614
$806,733
$1,538,614
$1,538,614
$1,538,614

Bulletin No. 2021–15

999

April 12, 2021

County Name
MONMOUTH
MORRIS
OCEAN
PASSAIC
SALEM
SOMERSET
SUSSEX
UNION
WARREN

State
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ

One-Unit
Limit
$799,948
$799,948
$799,948
$799,948
$419,489
$799,948
$799,948
$799,948
$362,439

Two-Unit
Limit
$1,024,284
$1,024,284
$1,024,284
$1,024,284
$536,995
$1,024,284
$1,024,284
$1,024,284
$463,992

Three-Unit
Limit
$1,238,041
$1,238,041
$1,238,041
$1,238,041
$649,151
$1,238,041
$1,238,041
$1,238,041
$560,827

Four-Unit
Limit
$1,538,614
$1,538,614
$1,538,614
$1,538,614
$806,733
$1,538,614
$1,538,614
$1,538,614
$697,009

CATRON
LOS ALAMOS
SANTA FE

NM
NM
NM

$390,405
$482,133
$402,710

$499,788
$617,197
$515,546

$604,113
$746,083
$623,179

$750,801
$927,205
$774,438

CARSON CITY
CLARK
DOUGLAS
STOREY
WASHOE

NV
NV
NV
NV
NV

$369,151
$352,371
$486,608
$447,455
$447,455

$472,552
$451,103
$622,936
$572,791
$572,791

$571,235
$545,263
$752,990
$692,389
$692,389

$709,898
$677,652
$935,814
$860,476
$860,476

BRONX
DUTCHESS
KINGS
NASSAU
NEW YORK
ORANGE
PUTNAM
QUEENS
RICHMOND
ROCKLAND
SUFFOLK
WESTCHESTER

NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY

$799,948
$346,778
$799,948
$799,948
$799,948
$346,778
$799,948
$799,948
$799,948
$799,948
$799,948
$799,948

$1,024,284
$443,905
$1,024,284
$1,024,284
$1,024,284
$443,905
$1,024,284
$1,024,284
$1,024,284
$1,024,284
$1,024,284
$1,024,284

$1,238,041
$536,606
$1,238,041
$1,238,041
$1,238,041
$536,606
$1,238,041
$1,238,041
$1,238,041
$1,238,041
$1,238,041
$1,238,041

$1,538,614
$666,854
$1,538,614
$1,538,614
$1,538,614
$666,854
$1,538,614
$1,538,614
$1,538,614
$1,538,614
$1,538,614
$1,538,614

DELAWARE
FAIRFIELD
FRANKLIN
HOCKING
LICKING
MADISON
MORROW
PERRY
PICKAWAY
UNION

OH
OH
OH
OH
OH
OH
OH
OH
OH
OH

$387,049
$387,049
$387,049
$387,049
$387,049
$387,049
$387,049
$387,049
$387,049
$387,049

$495,460
$495,460
$495,460
$495,460
$495,460
$495,460
$495,460
$495,460
$495,460
$495,460

$598,909
$598,909
$598,909
$598,909
$598,909
$598,909
$598,909
$598,909
$598,909
$598,909

$744,332
$744,332
$744,332
$744,332
$744,332
$744,332
$744,332
$744,332
$744,332
$744,332

April 12, 2021

1000

Bulletin No. 2021–15

County Name
BENTON
CLACKAMAS
CLATSOP
COLUMBIA
DESCHUTES
HOOD RIVER
JACKSON
MARION
MULTNOMAH
POLK
WASHINGTON
YAMHILL

State
OR
OR
OR
OR
OR
OR
OR
OR
OR
OR
OR
OR

One-Unit
Limit
$418,371
$503,387
$369,151
$503,387
$447,455
$464,235
$346,778
$357,964
$503,387
$357,964
$503,387
$503,387

Two-Unit
Limit
$535,585
$644,433
$472,552
$644,433
$572,791
$594,289
$443,905
$458,253
$644,433
$458,253
$644,433
$644,433

Three-Unit
Limit
$647,400
$778,961
$571,235
$778,961
$692,389
$718,360
$536,606
$553,921
$778,961
$553,921
$778,961
$778,961

Four-Unit
Limit
$804,544
$968,060
$709,898
$968,060
$860,476
$892,771
$666,854
$688,400
$968,060
$688,400
$968,060
$968,060

BUCKS
CARBON
CHESTER
DELAWARE
LEHIGH
MONTGOMERY
NORTHAMPTON
PHILADELPHIA
PIKE

PA
PA
PA
PA
PA
PA
PA
PA
PA

$419,489
$362,439
$419,489
$419,489
$362,439
$419,489
$362,439
$419,489
$799,948

$536,995
$463,992
$536,995
$536,995
$463,992
$536,995
$463,992
$536,995
$1,024,284

$649,151
$560,827
$649,151
$649,151
$560,827
$649,151
$560,827
$649,151
$1,238,041

$806,733
$697,009
$806,733
$806,733
$697,009
$806,733
$697,009
$806,733
$1,538,614

BRISTOL
KENT
NEWPORT
PROVIDENCE
WASHINGTON

RI
RI
RI
RI
RI

$492,201
$492,201
$492,201
$492,201
$492,201

$630,085
$630,085
$630,085
$630,085
$630,085

$761,647
$761,647
$761,647
$761,647
$761,647

$946,563
$946,563
$946,563
$946,563
$946,563

BEAUFORT
BERKELEY
CHARLESTON
DORCHESTER
JASPER

SC
SC
SC
SC
SC

$369,151
$402,710
$402,710
$402,710
$369,151

$472,552
$515,546
$515,546
$515,546
$472,552

$571,235
$623,179
$623,179
$623,179
$571,235

$709,898
$774,438
$774,438
$774,438
$709,898

CANNON
CHEATHAM
DAVIDSON
DICKSON
MACON
MAURY
ROBERTSON
RUTHERFORD

TN
TN
TN
TN
TN
TN
TN
TN

$570,506
$570,506
$570,506
$570,506
$570,506
$570,506
$570,506
$570,506

$730,325
$730,325
$730,325
$730,325
$730,325
$730,325
$730,325
$730,325

$882,800
$882,800
$882,800
$882,800
$882,800
$882,800
$882,800
$882,800

$1,097,141
$1,097,141
$1,097,141
$1,097,141
$1,097,141
$1,097,141
$1,097,141
$1,097,141

Bulletin No. 2021–15

1001

April 12, 2021

County Name
SMITH
SUMNER
TROUSDALE
WILLIAMSON
WILSON

State
TN
TN
TN
TN
TN

One-Unit
Limit
$570,506
$570,506
$570,506
$570,506
$570,506

Two-Unit
Limit
$730,325
$730,325
$730,325
$730,325
$730,325

Three-Unit
Limit
$882,800
$882,800
$882,800
$882,800
$882,800

Four-Unit
Limit
$1,097,141
$1,097,141
$1,097,141
$1,097,141
$1,097,141

ATASCOSA
BANDERA
BASTROP
BEXAR
CALDWELL
COLLIN
COMAL
DALLAS
DENTON
ELLIS
GUADALUPE
HAYS
HUNT
JOHNSON
KAUFMAN
KENDALL
MEDINA
PARKER
ROCKWALL
TARRANT
TRAVIS
WILLIAMSON
WILSON
WISE

TX
TX
TX
TX
TX
TX
TX
TX
TX
TX
TX
TX
TX
TX
TX
TX
TX
TX
TX
TX
TX
TX
TX
TX

$392,642
$392,642
$404,947
$392,642
$404,947
$400,473
$392,642
$400,473
$400,473
$400,473
$392,642
$404,947
$400,473
$400,473
$400,473
$392,642
$392,642
$400,473
$400,473
$400,473
$404,947
$404,947
$392,642
$400,473

$502,658
$502,658
$518,416
$502,658
$518,416
$512,677
$502,658
$512,677
$512,677
$512,677
$502,658
$518,416
$512,677
$512,677
$512,677
$502,658
$502,658
$512,677
$512,677
$512,677
$518,416
$518,416
$502,658
$512,677

$607,567
$607,567
$626,632
$607,567
$626,632
$619,677
$607,567
$619,677
$619,677
$619,677
$607,567
$626,632
$619,677
$619,677
$619,677
$607,567
$607,567
$619,677
$619,677
$619,677
$626,632
$626,632
$607,567
$619,677

$755,081
$755,081
$778,767
$755,081
$778,767
$770,158
$755,081
$770,158
$770,158
$770,158
$755,081
$778,767
$770,158
$770,158
$770,158
$755,081
$755,081
$770,158
$770,158
$770,158
$778,767
$778,767
$755,081
$770,158

BOX ELDER
DAVIS
JUAB
MORGAN
RICH
SALT LAKE
SUMMIT
TOOELE
UTAH
WASATCH
WASHINGTON
WEBER

UT
UT
UT
UT
UT
UT
UT
UT
UT
UT
UT
UT

$628,675
$628,675
$427,320
$628,675
$364,676
$440,744
$795,352
$440,744
$427,320
$795,352
$402,710
$628,675

$804,836
$804,836
$547,014
$804,836
$466,861
$564,231
$1,018,204
$564,231
$547,014
$1,018,204
$515,546
$804,836

$972,826
$972,826
$661,261
$972,826
$564,329
$682,029
$1,230,745
$682,029
$661,261
$1,230,745
$623,179
$972,826

$1,209,005
$1,209,005
$821,761
$1,209,005
$701,289
$847,587
$1,529,568
$847,587
$821,761
$1,529,568
$774,438
$1,209,005

April 12, 2021

1002

Bulletin No. 2021–15

County Name
ALBEMARLE
ALEXANDRIA CITY
AMELIA
ARLINGTON
CHARLES CITY
CHARLOTTESVILLE
CHESAPEAKE CITY
CHESTERFIELD
CLARKE
COLONIAL HEIGHT
CULPEPER
DINWIDDIE
FAIRFAX
FAIRFAX CITY
FALLS CHURCH CI
FAUQUIER
FLUVANNA
FRANKLIN CITY
FREDERICKSBURG
GLOUCESTER
GOOCHLAND

State
VA
VA
VA
VA
VA
VA
VA
VA
VA
VA
VA
VA
VA
VA
VA
VA
VA
VA
VA
VA
VA

One-Unit
Limit
$425,083
$799,948
$521,285
$799,948
$521,285
$425,083
$446,337
$521,285
$799,948
$521,285
$799,948
$521,285
$799,948
$799,948
$799,948
$799,948
$425,083
$446,337
$799,948
$446,337
$521,285

Two-Unit
Limit
$544,193
$1,024,284
$667,341
$1,024,284
$667,341
$544,193
$571,381
$667,341
$1,024,284
$667,341
$1,024,284
$667,341
$1,024,284
$1,024,284
$1,024,284
$1,024,284
$544,193
$571,381
$1,024,284
$571,381
$667,341

GREENE
HAMPTON CITY
HANOVER
HENRICO
HOPEWELL CITY
ISLE OF WIGHT
JAMES CITY
KING AND QUEEN
KING GEORGE
KING WILLIAM
LANCASTER
LOUDOUN
MADISON
MANASSAS CITY
MANASSAS PARK C
MATHEWS
NELSON
NEW KENT
NEWPORT NEWS CI
NORFOLK CITY
PETERSBURG CITY
POQUOSON CITY

VA
VA
VA
VA
VA
VA
VA
VA
VA
VA
VA
VA
VA
VA
VA
VA
VA
VA
VA
VA
VA
VA

$425,083
$446,337
$521,285
$521,285
$521,285
$446,337
$446,337
$521,285
$349,015
$521,285
$430,676
$799,948
$799,948
$799,948
$799,948
$446,337
$425,083
$521,285
$446,337
$446,337
$521,285
$446,337

$544,193
$571,381
$667,341
$667,341
$667,341
$571,381
$571,381
$667,341
$446,774
$667,341
$551,343
$1,024,284
$1,024,284
$1,024,284
$1,024,284
$571,381
$544,193
$667,341
$571,381
$571,381
$667,341
$571,381

Bulletin No. 2021–15

1003

Three-Unit
Limit
$657,759
$1,238,041
$806,636
$1,238,041
$806,636
$657,759
$690,686
$806,636
$1,238,041
$806,636
$1,238,041
$806,636
$1,238,041
$1,238,041
$1,238,041
$1,238,041
$657,759
$690,686
$1,238,041
$690,686

Four-Unit
Limit
$817,481
$1,538,614
$1,002,495
$1,538,614
$1,002,495
$817,481
$858,336
$1,002,495
$1,538,614
$1,002,495
$1,538,614
$1,002,495
$1,538,614
$1,538,614
$1,538,614
$1,538,614
$817,481
$858,336
$1,538,614
$858,336

$806,636
$657,759
$690,686
$806,636
$806,636
$806,636
$690,686
$690,686
$806,636
$540,059
$806,636
$666,417
$1,238,041
$1,238,041
$1,238,041
$1,238,041
$690,686
$657,759
$806,636
$690,686
$690,686
$806,636
$690,686

$1,002,495
$817,481
$858,336
$1,002,495
$1,002,495
$1,002,495
$858,336
$858,336
$1,002,495
$671,183
$1,002,495
$828,230
$1,538,614
$1,538,614
$1,538,614
$1,538,614
$858,336
$817,481
$1,002,495
$858,336
$858,336
$1,002,495
$858,336

April 12, 2021

County Name
PORTSMOUTH CITY
POWHATAN
PRINCE GEORGE
PRINCE WILLIAM
RAPPAHANNOCK
RICHMOND CITY
SOUTHAMPTON
SPOTSYLVANIA
STAFFORD
SUFFOLK CITY
SUSSEX
VIRGINIA BEACH
WARREN
WILLIAMSBURG CI
YORK

State
VA
VA
VA
VA
VA
VA
VA
VA
VA
VA
VA
VA
VA
VA
VA

One-Unit
Limit
$446,337
$521,285
$521,285
$799,948
$799,948
$521,285
$446,337
$799,948
$799,948
$446,337
$521,285
$446,337
$799,948
$446,337
$446,337

Two-Unit
Limit
$571,381
$667,341
$667,341
$1,024,284
$1,024,284
$667,341
$571,381
$1,024,284
$1,024,284
$571,381
$667,341
$571,381
$1,024,284
$571,381
$571,381

Three-Unit
Limit
$690,686
$806,636
$806,636
$1,238,041
$1,238,041
$806,636
$690,686
$1,238,041
$1,238,041
$690,686
$806,636
$690,686
$1,238,041
$690,686
$690,686

Four-Unit
Limit
$858,336
$1,002,495
$1,002,495
$1,538,614
$1,538,614
$1,002,495
$858,336
$1,538,614
$1,538,614
$858,336
$1,002,495
$858,336
$1,538,614
$858,336
$858,336

CHITTENDEN
FRANKLIN
GRAND ISLE

VT
VT
VT

$369,151
$369,151
$369,151

$472,552
$472,552
$472,552

$571,235
$571,235
$571,235

$709,898
$709,898
$709,898

CHELAN
CLALLAM
CLARK
DOUGLAS
ISLAND
KING
KITSAP
PIERCE
SAN JUAN
SKAGIT
SKAMANIA
SNOHOMISH
THURSTON
WHATCOM

WA
WA
WA
WA
WA
WA
WA
WA
WA
WA
WA
WA
WA
WA

$361,320
$373,625
$503,387
$361,320
$419,489
$755,081
$423,964
$755,081
$484,370
$394,879
$503,387
$755,081
$394,879
$430,676

$462,533
$478,291
$644,433
$462,533
$536,995
$966,649
$542,734
$966,649
$620,066
$505,527
$644,433
$966,649
$505,527
$551,343

$559,125
$578,141
$778,961
$559,125
$649,151
$1,168,442
$656,057
$1,168,442
$749,536
$611,068
$778,961
$1,168,442
$611,068
$666,417

$694,869
$718,506
$968,060
$694,869
$806,733
$1,452,090
$815,341
$1,452,090
$931,485
$759,361
$968,060
$1,452,090
$759,361
$828,230

KENOSHA
MILWAUKEE
OZAUKEE
PIERCE
ST. CROIX
WASHINGTON
WAUKESHA

WI
WI
WI
WI
WI
WI
WI

$369,151
$352,371
$352,371
$391,523
$391,523
$352,371
$352,371

$472,552
$451,103
$451,103
$501,199
$501,199
$451,103
$451,103

$571,235
$545,263
$545,263
$605,864
$605,864
$545,263
$545,263

$709,898
$677,652
$677,652
$752,941
$752,941
$677,652
$677,652

April 12, 2021

1004

Bulletin No. 2021–15

County Name
JEFFERSON

State
WV

One-Unit
Limit
$799,948

Two-Unit
Limit
$1,024,284

Three-Unit
Limit
$1,238,041

Four-Unit
Limit
$1,538,614

SHERIDAN
TETON

WY
WY

$476,540
$799,948

$610,047
$1,024,284

$737,426
$1,238,041

$916,408
$1,538,614

GUAM

GU

$548,133

$701,727

$848,220

$1,054,098

NORTHERN ISLAND
ROTA
SAIPAN
TINIAN

MP
MP
MP
MP

$510,099
$399,354
$514,574
$517,930

$652,993
$511,218
$658,732
$663,061

$789,321
$617,975
$796,276
$801,480

$980,949
$767,970
$989,557
$996,026

AGUAS BUENAS
AIBONITO
BARCELONETA
BARRANQUITAS
BAYAMON
CAGUAS
CANOVANAS
CAROLINA
CATANO
CAYEY
CEIBA
CIALES
CIDRA
COMERIO
COROZAL
DORADO
FAJARDO
FLORIDA
GUAYNABO
GURABO
HUMACAO
JUNCOS
LAS PIEDRAS
LOIZA
LUQUILLO
MANATI
MAUNABO
MOROVIS
NAGUABO
NARANJITO
OROCOVIS

PR
PR
PR
PR
PR
PR
PR
PR
PR
PR
PR
PR
PR
PR
PR
PR
PR
PR
PR
PR
PR
PR
PR
PR
PR
PR
PR
PR
PR
PR
PR

$374,744
$374,744
$374,744
$374,744
$374,744
$374,744
$374,744
$374,744
$374,744
$374,744
$374,744
$374,744
$374,744
$374,744
$374,744
$374,744
$374,744
$374,744
$374,744
$374,744
$374,744
$374,744
$374,744
$374,744
$374,744
$374,744
$374,744
$374,744
$374,744
$374,744
$374,744

$479,750
$479,750
$479,750
$479,750
$479,750
$479,750
$479,750
$479,750
$479,750
$479,750
$479,750
$479,750
$479,750
$479,750
$479,750
$479,750
$479,750
$479,750
$479,750
$479,750
$479,750
$479,750
$479,750
$479,750
$479,750
$479,750
$479,750
$479,750
$479,750
$479,750
$479,750

$579,892
$579,892
$579,892
$579,892
$579,892
$579,892
$579,892
$579,892
$579,892
$579,892
$579,892
$579,892
$579,892
$579,892
$579,892
$579,892
$579,892
$579,892
$579,892
$579,892
$579,892
$579,892
$579,892
$579,892
$579,892
$579,892
$579,892
$579,892
$579,892
$579,892
$579,892

$720,646
$720,646
$720,646
$720,646
$720,646
$720,646
$720,646
$720,646
$720,646
$720,646
$720,646
$720,646
$720,646
$720,646
$720,646
$720,646
$720,646
$720,646
$720,646
$720,646
$720,646
$720,646
$720,646
$720,646
$720,646
$720,646
$720,646
$720,646
$720,646
$720,646
$720,646

Bulletin No. 2021–15

1005

April 12, 2021

County Name
RIO GRANDE
SAN JUAN
SAN LORENZO
TOA ALTA
TOA BAJA
TRUJILLO ALTO
VEGA ALTA
VEGA BAJA
YABUCOA

State
PR
PR
PR
PR
PR
PR
PR
PR
PR

One-Unit
Limit
$374,744
$374,744
$374,744
$374,744
$374,744
$374,744
$374,744
$374,744
$374,744

Two-Unit
Limit
$479,750
$479,750
$479,750
$479,750
$479,750
$479,750
$479,750
$479,750
$479,750

Three-Unit
Limit
$579,892
$579,892
$579,892
$579,892
$579,892
$579,892
$579,892
$579,892
$579,892

Four-Unit
Limit
$720,646
$720,646
$720,646
$720,646
$720,646
$720,646
$720,646
$720,646
$720,646

ST. JOHN ISLAND
ST. THOMAS ISLA

VI
VI

$606,302
$434,032

$776,189
$555,623

$938,197
$671,621

$1,165,962
$834,699

$346,644

$443,832

$536,460

$666,708

All other areas ­ 2695 counties
(floor):

.02 The nationwide average purchase
price (for use in the housing cost/income
ratio for new and existing residences) is
$331,900.
SECTION 5. EFFECT ON OTHER
DOCUMENTS
Rev. Proc. 2020-18 is obsolete except
as provided in section 6 of this revenue
procedure.
SECTION 6. EFFECTIVE DATES
.01 Issuers may rely on this revenue
procedure to determine average area pur­
chase price safe harbors for commitments
to provide financing or issue mortgage
credit certificates that are made, or (if the
purchase precedes the commitment) for
residences that are purchased, in the pe­
riod that begins on March 25, 2021, and
ends on the date as of which the safe har­
bors contained in section 4.01 of this rev­
enue procedure are rendered obsolete by a
new revenue procedure.
.02 Notwithstanding section 5 of this
revenue procedure, issuers may continue
to rely on the average area purchase price
safe harbors contained in Rev. Proc. 202018, with respect to bonds sold, or for mort­
gage credit certificates issued with respect
to bond authority exchanged, before April

April 12, 2021

24, 2021, if the commitments to provide
financing or issue mortgage credit certifi­
cates are made on or before May 24, 2021.
.03 Except as provided in section 6.04,
issuers must use the nationwide average
purchase price limitation contained in this
revenue procedure for commitments to
provide financing or issue mortgage credit
certificates that are made, or (if the pur­
chase precedes the commitment) for res­
idences that are purchased, in the period
that begins on March 25, 2021, and ends
on the date when the nationwide average
purchase price limitation is rendered ob­
solete by a new revenue procedure.
.04 Notwithstanding sections 5 and
6.03 of this revenue procedure, issuers
may continue to rely on the nationwide
average purchase price set forth in Rev.
Proc. 2020-18 with respect to bonds sold,
or for mortgage credit certificates issued
with respect to bond authority exchanged,
before April 24, 2021, if the commitments
to provide financing or issue mortgage
credit certificates are made on or before
May 24, 2021.
SECTION 7. PAPERWORK
REDUCTION ACT
The collection of information con­
tained in this revenue procedure has been
reviewed and approved by the Office of

1006

Management and Budget in accordance
with the Paperwork Reduction Act (44
U.S.C. 3507) under control number 15451877.
An agency may not conduct or sponsor,
and a person is not required to respond
to, a collection of information unless the
collection of information displays a valid
OMB control number.
This revenue procedure contains a col­
lection of information requirement in sec­
tion 3.03. The purpose of the collection
of information is to verify the applicable
FHA loan limit that issuers of qualified
mortgage bonds and qualified mortgage
certificates have used to calculate the
average area purchase price for a given
metropolitan statistical area for purposes
of §§ 143(e) and 25(c). The collection of
information is required to obtain the ben­
efit of using revisions to FHA loan limits
to determine average area purchase prices.
The likely respondents are state and local
governments.
The estimated total annual reporting
and/or recordkeeping burden is: 15 hours.
The estimated annual burden per re­
spondent and/or recordkeeper: 15 min­
utes.
The estimated number of respondents
and/or recordkeepers: 60.
Books or records relating to a collec­
tion of information must be retained as

Bulletin No. 2021–15

long as their contents may become mate­
rial in the administration of any internal
revenue law. Generally, tax returns and tax
return information are confidential, as re­
quired by 26 U.S.C. 6103.
SECTION 8. DRAFTING
INFORMATION
The principal authors of this revenue
procedure are Jian H. Grant and David
White of the Office of Associate Chief
Counsel (Financial Institutions & Prod­
ucts). For further information regarding
this revenue procedure contact Mr. White
at (202) 317-4562 (not a toll-free number).
26 CFR 601.105: Examination of returns and
claims for refund, credit, or abatement; determination of correct tax liability.
(Also Part I, § 1391.)

Rev. Proc. 2021-18
SECTION 1. PURPOSE
This revenue procedure provides an au­
tomatic procedure for a State or local gov­
ernment in which an empowerment zone is
located to extend the empowerment zone
designation made under section 1391(a) of
the Internal Revenue Code (Code). Specif­
ically, this revenue procedure provides that
a State or local government that nominated
an empowerment zone is deemed to extend
until December 31, 2025, the termination
date designated by that State or local gov­
ernment in its empowerment zone nom­
ination (designated termination date), as
described in section 1391(d)(1)(B). This
revenue procedure further provides the
procedure for such State or local govern­
ment to decline this deemed extension of
its designated termination date.
SECTION 2. BACKGROUND
.01 Empowerment Zones. An empow­
erment zone is an area of high poverty
and unemployment located in an urban or
rural area that is designated under section
1391(a), as appropriate, by the Secretary
of Housing and Urban Development or
the Secretary of Agriculture, each Sec­
retary an “appropriate Secretary” under

Bulletin No. 2021–15

section 1393(a)(1) of the Code. See sec­
tion 1391(a); see generally section 1393.
Qualifying taxpayers and businesses lo­
cated within the boundaries of empow­
erment zones are eligible for Federal in­
come tax incentives to promote economic
development in those designated areas.
See section 1394 of the Code (regarding
tax-exempt enterprise zone facility bonds)
and section 1396 of the Code (regarding
empowerment zone employment credits).
.02 Empowerment Zone Designation
and Extensions.
(1) Initial designation. As originally
enacted in 1993, section 1391(d)(1) pro­
vided that the designation of an empow­
erment zone remained in effect during the
period beginning on the date of the desig­
nation and ending on the earliest of (i) the
close of the 10th calendar year beginning
on or after such date of designation (statu­
tory termination date), (ii) the termination
date designated by a State or local govern­
ment in its nomination (that is, the desig­
nated termination date), or (iii) the date
the appropriate Secretary revokes the des­
ignation. See section 13301(a) of the Om­
nibus Budget Reconciliation Act of 1993
(OBRA of 1993), Public Law 103-66, 107
Stat. 312 (August 10, 1993) (adding sec­
tion 1391(d)(1) to the Code).
(2) Extensions of statutory termination date and automatic extensions of
designated termination date. The statu­
tory termination date has been extended
multiple times, most recently in 2020 to
extend that date to December 31, 2025.
See section 118(a) of the Taxpayer Cer­
tainty and Disaster Tax Relief Act of 2020
(TCDTRA of 2020), enacted as part of
Title I of Division EE of the Consolidat­
ed Appropriations Act, 2021, Pub. L. No.
116-260, 134 Stat. 1182 (December 27,
2020). After each extension of the stat­
utory termination date and pursuant to
specific statutory grants of authority, the
Department of the Treasury (Treasury De­
partment) and the Internal Revenue Ser­
vice (IRS) issued guidance automatically
treating a designated termination date as
extended to the date of the amended stat­
utory termination date, unless the State or
local government declined the extension
in a written notification to the IRS. See,
for example, section 3 of Rev. Proc. 2020-

1007

16, 2020-27 I.R.B. 10 (deemed extension
to December 31, 2020); see also section 2
of Rev. Proc. 2020-16 (providing an over­
view of each extension of the statutory ter­
mination date).
(3) Current designated termination
date of all empowerment zones. The IRS
has received no written request from a
State or local government to decline any
extension of a designated termination
date otherwise provided in the previous
guidance described in section 2.02(2) of
this revenue procedure. Therefore, as of
March 26, 2021, all empowerment zones
have a designated termination date of
December 31, 2020, the latest statutory
termination date prior to enactment of the
TCDTRA of 2020.
.03 Statutory authority to extend current designated termination date. Section
118(d) of the TCDTRA of 2020 provides
that, if a nomination for an empower­
ment zone includes a designated termi­
nation date of December 31, 2020, sec­
tion 1391(d)(1)(B) does not apply to the
designation if, after the date of enactment
of the TCDTRA of 2020, the State or lo­
cal government that made such nomina­
tion amends the nomination to provide a
new termination date in such manner as
may be provided by the Secretary of the
Treasury (or the Secretary’s designee).
Accordingly, section 3.01 of this revenue
procedure sets forth an automatic exten­
sion procedure to extend a designated
termination date to December 31, 2025,
and section 3.02 of this revenue proce­
dure sets forth a written declination pro­
cedure consistent with the previous guid­
ance described above.
SECTION 3. AUTOMATIC
EXTENSION OF DESIGNATED
TERMINATION DATE
.01 Automatic extension. Subject to
declination by written notification pur­
suant to section 3.02 of this revenue pro­
cedure, the designated termination date
with regard to all empowerment zones
is deemed to be extended from Decem­
ber 31, 2020, to December 31, 2025.
Accordingly, the designated termination
date is deemed to be the same date as the
date provided in section 1391(d)(1)(A)(i)

April 12, 2021

(that is, December 31, 2025). Therefore,
section 1391(d)(1)(B) does not apply and
the designation of all empowerment zones
will remain in effect until December 31,
2025 (unless terminated at an earlier date
by the appropriate Secretary under section
1391(d)(1)(C)).
.02 Declination of automatic extension.
(1) In general. Pursuant to section
3.02(2) of this revenue procedure, a State
or local government may decline the ex­
tension of a designated termination date
described in section 3.01 of this revenue
procedure.
(2) Form and manner.
(a) Deadline for written notification. To
make a declination under section 3.02(1)
of this revenue procedure, not later than
May 25, 2021, the State or local govern­
ment must provide written notification to
the IRS that affirmatively declines the De­
cember 31, 2025, designated termination
date extension under section 3.01 of this
revenue procedure.
(b) Electronic delivery. This written
notification must be sent by electronic
facsimile to Bruce Chang, CC:ITA:B07,
at facsimile number (855) 576-2341.
SECTION 4. EFFECT ON OTHER
DOCUMENTS
Rev. Proc. 2020-16 is obsoleted for
taxable years beginning after 2020.
SECTION 5. EFFECTIVE DATE
This revenue procedure is effective for
taxable years beginning after December
31, 2020, the effective date of the amend­
ments made by section 118 of the TC­
DTRA of 2020.
SECTION 6. DRAFTING
INFORMATION
The principal author of this revenue
procedure is Bruce Chang of the Office
of Associate Chief Counsel (Income Tax
& Accounting). For further information
regarding this revenue procedure, contact
Mr. Chang at (202) 317-4870 (not a tollfree number).

April 12, 2021

26 CFR 601.601: Rules and Regulations.
(Also Part I, §§ 25, 143)

Rev. Proc. 2021-19
SECTION 1. PURPOSE
This revenue procedure provides guid­
ance with respect to the United States and
area median gross income figures for use
by issuers of qualified mortgage bonds, as
defined in § 143(a) of the Internal Reve­
nue Code, and issuers of mortgage credit
certificates, as defined in § 25(c), in com­
puting the income requirements described
in § 143(f).
SECTION 2. BACKGROUND
.01 Section 103(a) provides that, ex­
cept as provided in § 103(b), gross income
does not include interest on any State or
local bond. Section 103(b)(1) provides
that § 103(a) does not apply to any private
activity bond that is not a qualified bond
(within the meaning of § 141). Section
141(e) provides that the term “qualified
bond” includes any private activity bond
that (1) is a qualified mortgage bond, (2)
meets the applicable volume cap require­
ments under § 146, and (3) meets the ap­
plicable requirements under § 147.
.02 Section 143(a)(1) provides that the
term “qualified mortgage bond” means a
bond that is issued as part of a “qualified
mortgage issue”. Section 143(a)(2)(A)
provides that the term “qualified mort­
gage issue” means an issue of one or more
bonds by a State or political subdivision
thereof, but only if: (i) all proceeds of the
issue (exclusive of issuance costs and a
reasonably required reserve) are to be
used to finance owner-occupied residenc­
es; (ii) the issue meets the requirements of
subsections (c), (d), (e), (f), (g), (h), (i),
and (m)(7) of § 143; (iii) the issue does
not meet the private business tests of para­
graphs (1) and (2) of § 141(b); and (iv)
with respect to amounts received more
than 10 years after the date of issuance,
repayments of $250,000 or more of prin­
cipal on financing provided by the issue
are used not later than the close of the first
semi-annual period beginning after the
date the prepayment (or complete repay­
ment) is received to redeem bonds that are
part of the issue.

1008

.03 Section 25(c)(1) provides that the
term “mortgage credit certificate” means
any certificate that: (1) is issued under a
qualified mortgage credit certificate pro­
gram by the State or political subdivision
having the authority to issue a qualified
mortgage bond to provide financing on the
principal residence of the taxpayer; (2) is
issued to the taxpayer in connection with
the acquisition, qualified rehabilitation, or
qualified home improvement of the tax­
payer’s principal residence; (3) specifies
the certificate credit rate and the certified
indebtedness amount; and (4) is in such
form as the Secretary of the Treasury or
the Secretary’s delegate (Secretary) may
prescribe.
.04 Section 25(c)(2) provides that the
term “qualified mortgage credit certifi­
cate program” means any program under
which, among other requirements, the
indebtedness certified by mortgage cred­
it certificates meets the requirements of
§ 143(f). See § 25(c)(2)(A)(iii)(IV).
.05 Section 143(f) imposes eligibility
requirements concerning the maximum
income of mortgagors for whom financ­
ing may be provided by qualified mort­
gage bonds. Generally, under §§ 143(f)
(1) and 25(c)(2)(A)(iii)(IV), these income
requirements are met only if all owner-fi­
nancing under a qualified mortgage bond
and all certified indebtedness amounts un­
der a mortgage credit certificate program
are provided to mortgagors whose family
income is 115 percent or less of the ap­
plicable median family income. Under
§ 143(f)(3), in the case of targeted area res­
idences, the income limitation of § 143(a)
applies to 2/3 of the owner financing and
is treated as satisfied if the family income
of the mortgagor is 140 percent or less
of the applicable median family income.
Under § 143(f)(6), if there are fewer than
three individuals in the family of the mort­
gagor, the income limitation of § 143(a) is
reduced to 100 percent of the applicable
median family income and, in the case of
targeted area residences, the income lim­
itation of § 143(a) is satisfied if the family
income of the mortgagor is 120 percent or
less of the applicable median family in­
come.
.06 Section 143(f)(2) provides that, for
purposes of § 143(f), the family income
of mortgagors, and area median gross
income, are determined by the Secretary

Bulletin No. 2021–15

after taking into account the regulations
prescribed under section 8 of the United
States Housing Act of 1937 (if terminated,
a successor program) (Housing Act).
.07 Section 143(f)(4) provides that the
term “applicable median family income”
means, with respect to a residence, the
greater of (A) the area median gross in­
come for the area in which the residence is
located, or (B) the statewide median gross
income for the state in which the residence
is located.
.08 Section 143(f)(5) provides for an
upward adjustment of the income limita­
tions in certain high housing cost areas.
Under § 143(f)(5)(C), a high housing
cost area is a statistical area for which
the housing cost/income ratio is greater
than 1.2. The housing cost/income ratio
with respect to any statistical area is de­
termined under § 143(f)(5)(D) by dividing
(a) the applicable housing price ratio for
such area by (b) the ratio that the area me­
dian gross income for such area bears to
the median gross income for the United
States. The applicable housing price ratio
for any area is the new housing price ratio
(new housing average purchase price for
the area divided by the new housing aver­
age purchase price for the United States)
or the existing housing price ratio (exist­
ing housing average purchase price for the
area divided by the existing housing aver­
age purchase price for the United States),
whichever results in the housing cost/in­
come ratio being closer to 1.
.09 The Department of Housing and Ur­
ban Development (HUD) annually com­
putes the median gross income (adjust­
ed by family size) for the United States,
the states, and statistical areas within the
states. HUD releases the annually updated
income figures to its regional offices in a
notice. The most recent income figures are
generally available by calling the HUD
reference service at 1-800-245-2691, or at
HUD’s website, http://www.huduser.gov/
portal/datasets/il.html (including a menu
from which the year and type of data of
interest may be selected).
.10 Rev. Rul. 86-124, 1986-2 C.B. 27,
provides the manner in which the income
limits under § 143(f) applicable to quali­
fied mortgage bonds and mortgage credit
certificates are determined. In particular,
the revenue ruling provides that, for pur­
poses of § 143(f)(4), to determine the area

Bulletin No. 2021–15

median gross income for an area or state
in a manner consistent with the determi­
nation of “median gross income” for the
area or state under section 8 of the Hous­
ing Act, issuers must use the income limits
released by HUD for Lower Income and
Very Low Income under the Housing Act.
Further, Rev. Rul. 86-124 provides the
manner in which issuers must apply these
income limits. See generally, Rev. Rul.
86-124, Guidelines.
.11 The Internal Revenue Service (IRS)
has published a revenue procedure in the
Internal Revenue Bulletin annually, pro­
viding guidance with respect to the Unit­
ed States and area median gross income
figures that are to be used by issuers of
qualified mortgage bonds and issuers of
mortgage credit certificates for purposes
of computing the income requirements
under § 143(f). See, e.g., Rev. Proc. 202033, 2020-25 I.R.B. 956.
.12 The IRS has also published a rev­
enue procedure in the Internal Revenue
Bulletin annually, providing the most re­
cent nationwide average purchase prices
and average area purchase price safe har­
bor limitations for purposes of § 143(f)
(5). See, e.g., Rev. Proc. 2020-18, 2020-15
I.R.B. 592.
.13 The Department of the Treasury
(Treasury Department) and the IRS re­
quested public comments on whether, in­
stead of publishing a revenue procedure
annually, such as Rev. Proc. 2020-33, the
IRS should publish permanent guidance
that would allow issuers to rely on the
HUD income figures immediately upon
release. See Rev. Proc. 2020-33, Section
6. The Treasury Department and the IRS
also requested public comments on the
two-year convention with respect to the
issuers’ reliance on the HUD income fig­
ures, as provided in section 3.01 of Rev.
Proc. 2020-33, and a transition period, if
necessary. See Rev. Proc. 2020-33, Sec­
tion 6. Comments received consistently
favored publication of permanent guid­
ance, retention of the two-year conven­
tion, and provision of a transition period,
such as a period of 90 days following the
release of the HUD income figures. As a
result, the Treasury Department and the
IRS have decided to publish this revenue
procedure as permanent guidance consis­
tent with comments received and to cease
publishing annual revenue procedures

1009

providing income figures for purposes of
computing the income requirements of
§ 143(f).
SECTION 3. SCOPE
This revenue procedure applies to
mortgage loans financed with qualified
mortgage bonds and to mortgage credit
certificates.
SECTION 4. APPLICATION
.01 Applicable Income Figures. Except
as provided in section 4.02 of this revenue
procedure, for purposes of computing the
income requirements of § 143(f), issuers
of qualified mortgage bonds or mortgage
credit certificates must use either (1) the
income figures HUD released most recent­
ly (Most Recent HUD Figures) or (2) the
income figures HUD released immediate­
ly prior to the Most Recent HUD Figures
(Immediately Prior HUD Figures), deter­
mined as of the date a mortgage loan or
mortgage credit certificate is committed to
a mortgagor.
.02 Transition Period. For mortgage
loans and mortgage credit certificates
committed to mortgagors no later than 90
days after the date on which HUD releas­
es updated income figures for the calendar
year, issuers of qualified mortgage bonds
or mortgage credit certificates may contin­
ue to use the income figures HUD released
during the second preceding calendar year
for purposes of computing the income re­
quirements of § 143(f).
.03 Consistency Requirement. If an is­
suer uses the Most Recent HUD Figures
to compute the housing cost/income ratio
under § 143(f)(5), the issuer must use the
Most Recent HUD Figures for all purpos­
es under § 143(f). Likewise, if an issuer
uses the Immediately Prior HUD Figures
to compute the housing cost/income ratio
under § 143(f)(5), the issuer must use the
Immediately Prior HUD Figures for all
purposes under § 143(f). For example, if
an issuer uses the income figures HUD
released in 2021 to compute the housing
cost/income ratio under § 143(f)(5), the
issuer must use the income figures HUD
released in 2021 for all purposes under
§ 143(f). Likewise, if an issuer uses the
income figures HUD released in 2020 to
compute the housing cost/income ratio

April 12, 2021

under § 143(f)(5), the issuer must use the
income figures HUD released in 2020 for
all purposes under § 143(f).
SECTION 5. EFFECT ON OTHER
DOCUMENTS
.01 This revenue procedure obsoletes
Rev. Proc. 2020-33.

April 12, 2021

.02 This revenue procedure amplifies
Rev. Rul. 86-124.
SECTION 6. EFFECTIVE DATE
This revenue procedure is effective for
mortgage loans and mortgage credit cer­
tificates committed on or after March 25,
2021.

1010

DRAFTING INFORMATION
The principal authors of this revenue
procedure are Jian H. Grant and David
White of the Office of Associate Chief
Counsel (Financial Institutions & Prod­
ucts). For further information regarding
this revenue procedure contact Mr. White
at (202) 317-6980 (not a toll-free number).

Bulletin No. 2021–15

Part IV
Announcement and Report
Concerning
Advance Pricing Agreements
March 23, 2021

Announcement 2021-6
This Announcement is issued pursuant to § 521(b) of Pub. L. 106-170, the Ticket to Work and Work Incentives Improvement Act of
1999, which requires the Secretary of the Treasury to report annually to the public concerning advance pricing agreements (APAs)
and the Advance Pricing and Mutual Agreement Program (APMA Program), formerly known as the Advance Pricing Agreement
Program (APA Program). The first report covered calendar years 1991 through 1999. Subsequent reports covered each calendar year
2000 through 2019 separately. This twenty-second report describes the experience, structure, and activities of the APMA Program
during calendar year 2020. It does not provide guidance regarding the application of the arm’s length standard.
Part I of this report includes information on the structure, composition, and operation of the APMA Program; Part II presents statisti­
cal data; and Part III includes general descriptions of various elements of the APAs executed in 2020, including types of transactions
covered, transfer pricing methods used, and completion time.
John C. C. Hughes
Director, Advance Pricing and Mutual Agreement Program

Bulletin No. 2021–15

1011

April 12, 2021

Part I. The APMA Program – Structure, Composition, and Operation
[Pub. L. 106-170 § 521(b)(2)(A)]
In February 2012, the former APA Program was moved from the Office of Chief Counsel to the Office of Transfer Pricing Operations1
within the Large Business and International Division of the IRS and combined with the U.S. Competent Authority staff responsible
for transfer pricing cases, thereby forming the APMA Program.
In September 2018, APMA restructured its management and realigned its teams. As of December 31, 2020, the APMA Program com­
prised 64 team leaders, 21 economists, 9 managers, and 3 assistant directors. Each assistant director oversees 3 managers who lead
teams comprised of both team leaders and economists. The APMA Program’s main office is in Washington, DC, and it also has offices
in northern California (San Francisco and San Jose), southern California (Los Angeles and Laguna Niguel), Chicago, and New York.
On August 31, 2015, new revenue procedures governing requests under the mutual agreement procedure (MAP) and APA appli­
cations were published in 2015-35 I.R.B. on pages 236 and 263, respectively. Revenue Procedure (Rev. Proc.) 2015-41 provides
guidance and instructions on filing APA requests as well as guidance and information on the administration of APAs. Rev. Proc.
2015-41 updates and supersedes Rev. Proc. 2006-9, 2006-1 C.B. 278, as modified by Rev. Proc. 2008-31, 2008-1 C.B. 1133, which is
also superseded. Rev. Proc. 2015-40 provides procedures and guidance on requesting assistance from the U.S. Competent Authority
where the taxpayer believes that the actions of the United States or a treaty country result or will result in the taxpayer being subject
to taxation not in accordance with the applicable U.S. tax treaty. Rev. Proc. 2015-40 updates and supersedes Rev. Proc. 2006-54,
2006-2 C.B. 1035.
Model APAs appear as appendices to this report. Appendix 1 is the model for APAs covered by Rev. Proc. 2006-9. Appendix 2 is the
current model APA for APAs covered by Rev. Proc. 2015-41. A list of primary APMA contacts is available at https://www.irs.gov/
businesses/corporations/apma-contacts.

1

In 2017, Transfer Pricing Operations became Treaty & Transfer Pricing Operations.

April 12, 2021

1012

Bulletin No. 2021–15

Part II. APMA Program Statistical Data

Part II. APMA Program Statistical Data

[Pub.
L. 106-170 § 521(b)(2)(C)(i-viii)]
[Pub. L. 106-170 § 521(b)(2)(C)(i-viii)]

Table
1: APA Applications
Filed
Table 1:
APA Applications
Filed
2
§ 521(b)(2)(C)(i)
§ 521(b)(2)(C)(i)
Filed 1991­1999
Filed 1991­1999
Filed 2000­2019
Filed 2000­2019
Filed inFiled
2020 in 2020
Total Filed 1991-2020
2

Unilateral
Unilateral

2

Total Filed 1991-2020

Bilateral
Bilateral Multilateral
MultilateralTotal Total
401 401
622 622
1,6211,621
26 26 2,2692,269
15 15
103 103
3
3 121 121
2,791

2,791

APA Applications Filed
2011-2020
250
200
150
100
50
0

2011 2012 2013 2014 2015 2016 2017 2018 2019 2020

Bilateral APA Applications Filed
by Country
All Other Countries
18%
United Kingdom
4%

Japan
41%

Korea
4%
Switzerland
5% Germany
7%

India
11%

Canada
10%

Theabove
chartsillustrate
abovethe
illustrate
numberapplications
of complete
filed
per year
andreceived
the bilateral
The charts
number the
of complete
filedapplications
per year and the
bilateral
requests
in 2020 by foreign
requests
received
2020
by foreign
Asuser
of fee
December
2020,
APMA
had also
country.
As of December
31,in2020,
APMA
had alsocountry.
received 25
filings that31,
were
not yet
accompanied
by substantially com­
plete APA
applications,
in addition
to thethat
121were
complete
applications. by substantially complete APA
received
25 user
fee filings
notAPA
yet accompanied
applications, in addition to the 121 complete APA applications.
2

The first APA Statutory Report, which compiled APA data from 1991­1999, did not report the cumulative number
of applications for those years by submission type, so the cumulative totals cannot be reported in that manner.

3
The first APA Statutory Report, which compiled APA data from 1991­1999, did not report the cumulative number of applications for those years by submission type, so the cumulative totals
cannot be reported in that manner.

2

Bulletin No. 2021–15

1013

April 12, 2021

3

3
and
Pending APAs
2: Executed
Table 2:Table
Executed
and Pending
APAs
§ 521(b)(2)(C)(ii-vi)
§ 521(b)(2)(C)(ii-vi)45

Total Executed
1991­2019 1991­2019
Total Executed
Total Executed
in 2020 in 2020
Total Executed
Total Executed
1991-2020 1991-2020
Total Executed

UnilateralBilateral
Bilateral
MultilateralTotal Total
Unilateral
Multilateral
643 643 1,280 1,280
17
17 1,940 1,940
19
105 105
3
127 127
19
3
662 662 1,385 1,385
20
20 2,067 2,067

Total Pending
as of 12/31/2020
Total Pending
as of 12/31/2020

43

43

384

384

21

21

448

448

Renewals Executed in 20204
Renewals Executed in 2020 4
Renewals Pending5 as of 12/31/2020
5

11
25

11
25

64
154

64
154

0
8

0
8

75
187

75
187

Renewals Pending as of 12/31/2020

Executed APAs
2011-2020
150
100
50
0

2011 2012 2013 2014 2015 2016 2017 2018 2019 2020

Executed Bilateral APAs
by Country
All Other Countries
18%

Japan
52%

Denmark
4%
United Kingdom
7%
Canada
8%

India
11%

2020,
the percentage
renewals
executed
remained(59
fairly
consistent
(59 percent
in in
2020
In 2020,Inthe
percentage
of renewals of
executed
remained
fairly consistent
percent
in 2020 versus
57 percent
2019). The charts
above illustrate
the total
number
of APAsThe
executed
perabove
year and
the countries
involved
in the executed
APAs.
versus 57
percent
in 2019).
charts
illustrate
the total
number
of APAsbilateral
executed
per
3

Executed APAs refer to all APAs finalized or renewed.
The number of renewals executed is included in the total number of APAs executed during the year.
5
The number of renewals still pending as of year­end is also included in the total number of pending APAs.
4

4

Executed APAs refer to all APAs finalized or renewed.
The number of renewals executed is included in the total number of APAs executed during the year.
5
The number of renewals still pending as of year­end is also included in the total number of pending APAs.
3
4

April 12, 2021

1014

Bulletin No. 2021–15

year and the countries involved in the executed bilateral APAs.
Pending APAs
2011-2020
500
400
300
200
100
0

2011 2012 2013 2014 2015 2016 2017 2018 2019 2020

Pending Bilateral APAs
by Country
All Other Countries
16%
United Kingdom
4%
Italy
4%
Mexico
5%

Japan
25%

Korea
5%

India
20%

Canada
11%

Germany
10%

top
chart illustrates,
numberrequests
of pending
requests
slightly relative
As theAs
topthe
chart
illustrates,
the numberthe
of pending
decreased
slightlydecreased
relative to December
31, 2019.toAs of December 31,
2020, over
half of the
APA requests31,
involved
India,
Canada.bilateral APA requests
December
31,pending
2019. bilateral
As of December
2020,either
overJapan,
half of
the or
pending
involved either Japan, India, or Canada.

Table 3: APAs Revoked or Cancelled and Applications Withdrawn
§ 521(b)(2)(C)(vii)67

Table 3: APAs Revoked or Cancelled and Applications Withdrawn
Unilateral
Bilateral
Multilateral
Total
§ 521(b)(2)(C)(vii)
Revoked or Cancelled in 2020
0
0
0
0
Unilateral
Bilateral
Multilateral
Total
6
11
Total Revoked or Cancelled 1991-2020
Revoked or Cancelled in 2020
0
0
0
0
6
Total Revoked or Cancelled 1991-2020
11
Applications Withdrawn in 2020
Total Applications Withdrawn 1991-20207

2

Applications Withdrawn in 2020
Total Applications Withdrawn 1991-2020 7

5

2

0

5

0

7
272

7
272

6

The first APA Statutory Report, which compiled APA data from 1991­1999, did not report the cumulative number
of applications for those years by submission type, so the cumulative totals cannot be reported in that manner.
7
See supra note 6.

5
The first APA Statutory Report, which compiled APA data from 1991­1999, did not report the cumulative number of applications for those years by submission type, so the cumulative totals
cannot be reported in that manner.
See supra note 6.

6

7

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April 12, 2021

Table 4: APAs Executed in 2020 by Industry

Table 4: APAs Executed in 2020 by Industry
§ 521(b)(2)(C)(viii)
§ 521(b)(2)(C)(viii)

Manufacturing

Industry

Industry

Manufacturing
Wholesale/Retail
Trade
Wholesale/Retail
Trade
Services Services
Finance, and
Insurance,
and Real Estate
Finance, Insurance,
Real Estate
Management
Management
Other Industries
All OtherAll
Industries

43
40
22
11
9
2

43
40
22
11
9
2

APAs Executed
in 2020 by Industry
Wholesale/Retail
Trade
31%

Manufacturing
34%

Services
17%
Finance, Insurance
and Real Estate
9%

All Other Industries
2%
Management
7%
Table 4a: Manufacturing APAs Executed in 2020

Table 4a: Manufacturing
ManufacturingAPAs Executed in 2020
Manufacturing
Chemical Manufacturing
8
Transportation
Equipment
Manufacturing
8
Chemical
Manufacturing
Miscellaneous
Manufacturing
7
Transportation
Equipment Manufacturing
Food Manufacturing
6
Miscellaneous Manufacturing
Computer and Electronic Product Manufacturing
5
Food Manufacturing
Machinery Manufacturing
3
Computer and Electronic Product Manufacturing
Plastics and Rubber Products Manufacturing
3
Machinery
Manufacturing
All Other Manufacturing
3
Plastics and Rubber Products Manufacturing
All Other Manufacturing
Manufacturing APAs
Executed in 2020
Chemical
Manufacturing
All Other
19%
Manufacturing
7%
Plastics and Rubber
Products
Manufacturing
7%
Machinery
Manufacturing
7%

6

Table 4b: Wholesale/Retail Trade APAs Executed in 2020
Wholesale/Retail Trade
April 12, 2021
1016
Merchant Wholesalers, Durable Goods
24

8
8
7
6
5
3
3
3
Transportation
Equipment
Manufacturing
19%

Miscellaneous
Manufacturing
16%
Food Manufacturing
14%
Computer and
Electronic Product
Manufacturing
11%

Bulletin No. 2021–15

Products
Manufacturing
7%
Machinery
Manufacturing
7%
Table 4b: Wholesale/Retail Trade APAs Executed in 2020

14%
Computer and
Electronic Product
Manufacturing
11%

Table 4b: Wholesale/Retail
Trade APAs Executed in 2020
Wholesale/Retail Trade
Wholesale/Retail
Trade
Merchant Wholesalers, Durable
Goods
24
Merchant
Wholesalers,
Durable
Goods
Merchant Wholesalers, Nondurable Goods
8 24
Merchant
Wholesalers,
8
Electronics
and Appliance
Stores Nondurable Goods
5
Electronics
5
All Other
Wholesalersand Appliance Stores
3
All Other Wholesalers
3

All Other
Wholesalers
8%

Wholesale/Retail Trade APAs
Executed in 2020

Electronics and
Appliance Stores
12%

Merchant
Wholesalers, Durable
Goods
60%

Merchant
Wholesalers,
Nondurable Goods
20%

Part III. General Descriptions of APAs Executed in 2020
[Pub.
L.General
106-170
§ 521(b)(2)(D)
(E)] in 2020
Part III.
Descriptions
of APAsand
Executed

Nature of the Relationships

[Pub. L. 106-170 § 521(b)(2)(D) and (E)]

Nature
of the Relationships
§ 521(b)(2)(D)(i)
§ 521(b)(2)(D)(i)

Relationships between
Controlled Parties
U.S. Parent & Non­
U.S. Subsidiary
27%
Sister Companies
11%

7
Non­U.S. Parent &
U.S. Subsidiary
61%

All Other
Relationships
1%

As in prior years, more than half of the APAs executed in 2020 involved transactions between non­U.S. parents and U.S. subsidiaries.

As in prior years, more than half of the APAs executed in 2020 involved transactions between
non­U.S. parents and U.S. subsidiaries.
Covered Transactions, Functions and Risks, and Tested Parties
§ 521(b)(2)(D)(ii-iii)
Types of Covered Transactions

Sale of Tangible
Property into the U.S.
25%
All Other
Types of
Bulletin
No. 2021–15
Transactions

1017

Provision of Services
by a U.S. Entity
19%
Provision of Services
by a Non­U.S. Entity

April 12, 2021

As in prior years, more than half of the APAs executed in 2020 involved transactions between
non­U.S. parents and U.S. subsidiaries.
Covered
Transactions,
Functions
and
Risks,
and Tested Parties
Covered
Transactions,
Functions and
Risks, and
Tested
Parties
§
521(b)(2)(D)(ii-iii)
§ 521(b)(2)(D)(ii-iii)
Types of Covered Transactions
Sale of Tangible
Property into the U.S.
25%
All Other Types of
Transactions
3%
Use of Intangible
Property by a Non­
U.S. Entity
6% Sale of Tangible
Property from the
U.S.
10%

Provision of Services
by a U.S. Entity
19%
Provision of Services
by a Non­U.S. Entity
19%

Use of Intangible
Property by a U.S.
Entity
18%

8

most
the transactions
covered
in in
APAs
executed
involve
theorsale
of risks.
InAlthough
the
majority
ofofAPAs,
transactions
involve
numerous
functions
and
8 the covered
Although
most
of the
transactions
covered in APAs
executed
2020
involve
the in
sale2020
ofbusiness
tangible
goods
the provision
of services,
tangible
goods
or
the
provision
of
services,
approximately
25
percent
of
transactions
covered
in can be
For
instance,
with
respect
to
functions,
APAs
involving
manufactured
products
typically
involve
approximately 25 percent of transactions covered in APAs executed in 2020 involve the use of intangible property,
which
executed
inthat
2020
involve
the useinventory.
ofand
intangible
property,
which
can beinamong
thedesign
most
among
the
most
challenging
transactions
in APMA’s
aAPAs
controlled
group
conducts
research
development
(R&D),
engages
product
challenging
transactions
in APMA’s
inventory.
and
engineering,
manufactures
the product,
markets and distributes the product, and performs

In thesupport
majority functions
of APAs, thesuch
covered
transactions
involve
business functions
and risks.
For the
instance,
with respect to func­
as legal,
finance,
andnumerous
human resources.
Regarding
risks,
controlled
8
tions, APAs
involving
manufactured
products
typically
involve a controlled group that conducts research and development (R&D),
APAs
often
cover
more
than
one
type
of
transaction.
group may assume a variety of risks, including market risks, R&D risks, financial risks, credit
engages in product design and engineering, manufactures the product, markets and distributes the product, and performs support
and such
collection
product
liability
risks,
and general
business
risks.
Inmay
theassume
APA evaluation
functions
as legal,risks,
finance,
and human
resources.
Regarding
risks, the
controlled
group
a variety of risks, including
process,
a
significant
amount
of
time
and
effort
is
devoted
to
understanding
how
the functions
8 product liability risks, and general business
market risks, R&D risks, financial risks, credit and collection risks,
risks. In the APA eval­
risksa are
allocated
amongst
controlled
group
of companies
are partyand
to risks
the covered
uationand
process,
signifi
cant amount
of time the
and effort
is devoted
to understanding
howthat
the functions
are allocated amongst
the controlled
group For
of companies
are partyselection
to the covered
Forthe
methods
selection
of a tested party, the
transactions.
methodsthat
requiring
of a transactions.
tested party,
testedrequiring
party that
is chosen
testedgenerally
party that iswill
chosen
generally
be the least
complex
of the controlled
taxpayers.
be the
least will
complex
of the
controlled
taxpayers.

Types of Tested Parties
U.S. Distributor
41%
U.S. Service Provider
17%

All Othey Types of
Tested Parties
1%
Non­U.S. Distributor
10%

U.S. Manufacturer
15%

Non­U.S. Service
Provider
16%

9
Consistent
with prior
years,
a majority
parties
2020 parties
were U.S.
distributors,
U.S.
manufacturers,
or U.S.
service providers.
Consistent
with
prior
years,ofa tested
majority
of9 in
tested
in
2020 were
U.S.
distributors,
U.S.

manufacturers, or U.S. service providers.
Transfer Pricing Methods Used
§ 521(b)(2)(D)(iv)

In 2020, the most commonly used transfer pricing method (TPM) for both the sale of tangible
property and the use of intangible property continued to be the comparable profits
method/transactional net margin method (CPM/TNMM). The CPM/TNMM was used for 84
percent of transfers of tangible and intangible property.
April 12, 2021
1018
Bulletin No. 2021–15
For covered transfers of tangible and intangible property that used the CPM/TNMM, the
8
9

APAs often cover more than one type of transaction.
Not all the executed APAs involve a tested party.

Transfer Pricing Methods Used
§ 521(b)(2)(D)(iv)
In 2020, the most commonly used transfer pricing method (TPM) for both the sale of tangible property and the use of intangible
property continued to be the comparable profits method/transactional net margin method (CPM/TNMM). The CPM/TNMM was used
for 84 percent of transfers of tangible and intangible property.
For covered transfers of tangible and intangible property that used the CPM/TNMM, the operating margin (OM) is still the most com­
mon profit level indicator (PLI) used to benchmark results. It was used 69 percent of the time. Other PLIs, such as the Berry Ratio and
net cost plus, made up the other 31 percent. As used here, “OM” is defined as the ratio of operating profit to sales,10 and “Berry Ratio”
is defined as the ratio of gross profit to operating expenses.11 Most services transactions (85 percent) also used the CPM/TNMM with
the OM and operating profit to operating expense being the most common PLIs (used 57 percent of the time).12
Sources of Comparables, Comparables Selection Criteria, and Nature of Adjustments to Comparables or Tested Party Data
§ 521(b)(2)(D)(v-vii)
For the APAs executed in 2020 that involved CPM/TNMM with a North American tested party, the most widely used data source for
comparables was Standard and Poor’s Compustat/Capital IQ database. Different sources were used in other cases (e.g., where the
tested party was not a U.S. or Canadian entity or where transaction-based methods were applied). The other most commonly used
databases are listed in the table below.
Table 5: Sources of Comparable Data
Avention (formerly known as OneSource)
Bloomberg
Bureau van Dijk (BvD)
Global Vantage
ktMINE
LoanConnector

Mergent
Orbis
Prowess
RoyaltySource
RoyaltyStat
Worldscope

In making comparability adjustments, typical balance sheet adjustments, as identified in Treas. Reg. §§ 1.482-1(d)(2) and 1.482-5(c)
(2)(iv), were made in most cases, including adjustments for differing amounts of payables, receivables, and inventory. Where appro­
priate, adjustments for different accounting practices were made to convert from LIFO to FIFO inventory accounting, and a small
number of cases also involved the accounting reclassification of expenses, e.g., from COGS to operating expenses.
Ranges, Goals, and Adjustment Mechanisms
§ 521(b)(2)(D)(viii-ix)
Most transactions covered in APAs target an interquartile range as described in Treas. Reg. § 1.482-1(e)(2)(iii)(C). Where the trans­
action involves a royalty payment for the use of intangible property, both specific royalty rates and ranges have been used. Where the
covered transaction is the sale or license of intangible property, and the payment for such transfer would be a royalty based solely on
external comparable uncontrolled transactions, a secondary or confirming method, e.g., a test of the post-royalty operating margin
or cost-plus mark-up, has sometimes also been used. The testing periods of the APAs executed in 2020 were either a single year, the
term of the APA only, or the term of the APA plus rollback years.
APAs executed in 2020 included several mechanisms for making adjustments to the tested party results when the results fall outside
the range or do not match the point required by the APA. Examples of the mechanisms used are an adjustment bringing the tested
party’s results to the closer edge of the range applied to the results of a single year, an adjustment to the closer edge of the range
applied to the results over the APA term, an adjustment to the specified point or royalty rate, or an adjustment to the median of the
range for a single year.

10
11
12

See Treas. Reg. § 1.482-5(b)(4)(ii)(A).
See Treas. Reg. § 1.482-5(b)(4)(ii)(B).
The majority of APAs that covered services transactions also included tangible/intangible transactions and are not tested under a separate PLI.

Bulletin No. 2021–15

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April 12, 2021

Critical Assumptions
§ 521(b)(2)(D)(v)
The model APAs used by the IRS (included as Appendix 1 of this report) include standard critical assumptions that there will be no
material changes to the taxpayer’s business or to its tax or financial accounting practices during the APA term. A few bilateral cases
have also included critical assumptions tied to the taxpayer’s profitability in a certain year or over the term of the APA. Pursuant to
§ 7.06(3) of Rev. Proc. 2015-41, APMA will cancel an APA in the event of a failure of a critical assumption unless the parties agree
to revise the APA.
Term Lengths of APAs Executed in 2020
§ 521(b)(2)(D)(x)
Table 6: Term Lengths of APAs Executed in 2020
Term Length
(years)
1
2
3
4
5
6
7
8
9
14
Average

Number of
APAs
1
2
3
4
62
15
24
11
4
1
6

As described in § 3.03(1) of Rev. Proc. 2015-41, taxpayers should request an APA term that would cover at least five prospective
years and may also request that the APA be “rolled back” to cover one or more earlier taxable years, although the appropriate
APA term is decided on a case-by-case basis. Of the APAs executed in 2020, 11 percent included rollback years. A substantial number
of those APAs with terms of greater than five years were submitted as a request for a five-year term, and the additional years were
agreed to between the taxpayer and the IRS (or, in the case of a bilateral APA, between the IRS and the foreign government upon the
taxpayer’s request) to ensure a reasonable amount of prospectivity in the APA term.
Amount of Time Taken to Complete New and Renewal APAs
§ 521(b)(2)(E)
Table 7: Months to Complete New and Renewal APAs Executed in 2020

New
Renewal
New & Renewal

April 12, 2021

Unilateral
Average
Median
36.2
35.3
25.4
21.0
29.0
24.0

Bilateral
Average
Median
50.8
43.7
34.1
30.3
40.1
36.3

1020

Unilateral & Bilateral
Average
Median
48.9
43.7
32.8
29.6
38.5
32.7

Bulletin No. 2021–15

New
Renewal
New & Renewal

36.2
25.4
29.0

35.3
21.0
24.0

50.8
34.1
40.1

48.9
32.8
38.5

43.7
30.3
36.3

43.7
29.6
32.7

Months to Complete New and Renewal APAs Executed in 2020

Months to Complete New and Renewal APAs Executed in 2020
Months to Complete

60.0

New

50.0
40.0

Renewal

30.0

New &
Renewal

20.0
10.0
0.0

Average

Median

Unilateral

Average

Median

Bilateral
Type of APA

Average

Median

Unilateral &
Bilateral

The median time required to complete an APA continued to decrease in 2020 to 32.7 months

The median
complete
an APA
(fromtime
38.8required
monthsto in
2019 and
40.2continued
monthstoindecrease
2018). in 2020 to 32.7 months (from 38.8 months in 2019 and 40.2
months in 2018).

Efforts
to Ensure
Compliance
Efforts
to Ensure
Compliance
with APAs with APAs
§
521(b)(2)(F)
§ 521(b)(2)(F)
As described
in § 7.02(1)
Rev. Proc.
2015­41,
taxpayers
are required
to fiare
le annual
reports
compliance
As described
in §of7.02(1)
of Rev.
Proc.
2015­41,
taxpayers
required
to to
filedemonstrate
annual reports
to with the
terms demonstrate
and conditions of
their APAs. The
review
these annual of
reports
criticalThe
partsfiling
of the APA
annual
comp

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Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/agency%3Airs%3A72b9880dea606310. Public record. Not legal advice.