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The greater that the income and appreciation generated by the assets transferred into the split interest trust exceeds the applicable federal rate, the more wealth that can be transferred to children and descendants at the termination of the trust.
7520 rate, which the IRS publishes each month along with the applicable federal rates (AFR).
For example, a client can use the Applicable Federal Rates (AFR) to lock in low imputed federal interest rates for intermediate- and long-term private premium financing, which makes easy, low-cost funding possible for a large life insurance policy that can be excluded from an estate.
The rate of interest on under- and overpayments should equal the applicable federal rate plus no more than two or three percentage points.
Section 7872 generally provides that a below-market interest rate loan has an original issue discount (OLD) equal to the present value difference between the discounted loan payments, and imputed payments at the applicable federal rate.
Ask your accountant or tax professional for the applicable federal rate (AFR).
Interest on the unpaid accrued interest amount shall accrue based on the effective Applicable Federal Rate and shall be paid in full on the maturity date.
The new issue price is determined by calculating the present value of all payments under the new debt at the applicable federal rate back to the date of the modification.