Low-income housing credit; satisfactory bond;
“bond factor” amounts for the period January through June 2006. This
ruling provides the monthly bond factor amounts to be used by taxpayers who
dispose of qualified low-income buildings or interests therein during the
period January through June 2006.
In Rev. Rul. 90-60, 1990-2 C.B. 3, the Internal Revenue Service provided
guidance to taxpayers concerning the general methodology used by the Treasury
Department in computing the bond factor amounts used in calculating the amount
of bond considered satisfactory by the Secretary under § 42(j)(6)
of the Internal Revenue Code. It further announced that the Secretary would
publish in the Internal Revenue Bulletin a table of bond factor amounts for
dispositions occurring during each calendar month.
Rev. Proc. 99-11, 1999-1 C.B. 275, established a collateral program
as an alternative to providing a surety bond for taxpayers to avoid or defer
recapture of the low-income housing tax credits under § 42(j)(6).
Under this program, taxpayers may establish a Treasury Direct Account and
pledge certain United States Treasury securities to the Internal Revenue Service
as security.
This revenue ruling provides in Table 1 the bond factor amounts for
calculating the amount of bond considered satisfactory under § 42(j)(6)
or the amount of United States Treasury securities to pledge in a Treasury
Direct Account under Rev. Proc. 99-11 for dispositions of qualified low-income
buildings or interests therein during the period January through June 2006.
For a list of bond factor amounts applicable to dispositions occurring
during other calendar years, see: Rev. Rul. 98-3, 1998-1 C.B. 248; Rev. Rul.
2001-2, 2001-1 C.B. 255; Rev. Rul. 2001-53, 2001-2 C.B. 488; Rev. Rul. 2002-72,
2002-2 C.B. 759; Rev. Rul. 2003-117, 2003-2 C.B. 1051; Rev. Rul. 2004-100,
2004-2 C.B. 718; and Rev. Rul. 2005-67, 2005-43 I.R.B. 771.
The principal author of this revenue ruling is David McDonnell of the
Office of Associate Chief Counsel (Passthroughs and Special Industries).
For further information regarding this revenue ruling, contact Mr. McDonnell
at (202) 622-3040 (not a toll-free call).
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