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.These monthly indexes are cumulated on a semiannual basis, and are published in the last Bulletin of each semiannual period.Section 6621 of the Internal Revenue Code establishes the interest rates on overpayments and underpayments of tax.Margin Financing Facility is a credit line granted to clients by Kim Eng Securities Hong Kong Limited to finance the purchase of securities.It is secured by a pledge of cash and /or marginable shares as collateral and is extended to both individual and corporate investors.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.
Under section 6621(a)(2), the underpayment rate is the sum of the federal short-term rate plus 3 percentage points.
Section 6621(c) provides that for purposes of interest payable under section 6601 on any large corporate underpayment, the underpayment rate under section 6621(a)(2) is determined by substituting “5 percentage points” for “3 percentage points.” See section 6621(c) and section 301.6621–3 of the Regulations on Procedure and Administration for the definition of a large corporate underpayment and for the rules for determining the applicable date.
Section 6621(c) and section 301.6621–3 are generally effective for periods after December 31, 1990.
This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for June 2015 used under § 417(e)(3)(D), the 24-month average segment rates applicable for June 2015, and the 30-year Treasury rates.
These rates reflect the application of § 430(h)(2)(C)(iv), which was added by the Moving Ahead for Progress in the 21st Century Act, Public Law 112–141 (MAP–21) and amended by section 2003 of the Highway and Transportation Funding Act of 2014 (HATFA).