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A bill to amend the Internal Revenue Code of 1954 to simplify the imputed interest rules of sections 1274 and 483, and for other purposes.

Public Law 99-121 · H.R. 2475 · 99th Congress · began in the House

Signed by Ronald Reagan (R) on Oct 11, 1985 · Taxation

Sponsor: Rep. Daniel Rostenkowski (D-IL-8)

Cosponsors (25): Rep. Jake Pickle,

Passage votes

  • HouseVoice vote
  • SenateVoice vote
Data notes

The final version of the law, as each chamber passed it. A chamber that passed it by voice vote or unanimous consent has no count. “Method not stated” means the record does not say how the chamber voted. Where the record has a member-by-member vote, the “Who voted for it” section shows who voted yea.

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Summary

The Congressional Research Service’s plain-language summary of what the law does.

Title I: Amendments to Imputed Interest Rules - Amends the Internal Revenue Code to reduce the imputation rate on seller-financed transactions from 120 percent to 100 percent of the Federal rate. Eliminates the separate testing rate for the determination of imputed interest. Directs the Secretary of the Treasury to make a determination of the Federal short-term, mid-term, and long-term rates on a monthly basis. Permits the use of a lower rate than the applicable Federal rate where such rate is based on the same principles as the applicable Federal rate and is appropriate for the terms of the instrument. Provides that the rate applicable to the sale or exchange shall be the lowest three-month rate.

Requires that an imputed interest rate of 110 of the applicable Federal rate (AFR) applies to sale-leaseback transactions.

Provides that the rate used to test the adequacy of stated interest on the first $2,800,000 of seller financing shall not exceed nine percent. Provides for an inflation adjustment for the $2,800,000 amount for purposes of the nine percent rate beginning after 1989.

Allows the parties to elect to account for interest using the cash method of accounting where the transaction amount of seller-financing is not more than $2,000,000.

Lengthens to 19 years the recovery period for which real property may be depreciated on an accelerated basis.

Exempts the imputed interest rules from certain workout arrangements in connection with loans involving the New York State Mortgage Loan Enforcement and Administration Corporation.

Title II: Amendments to Below-Market Interest Rules - Exempts from the below-market interest rate rules for any calendar year, below-market loans made by a lender to a qualified continuing care facility pursuant to a continuing care contract if the lender has attained age 65 before the close of such year. Provides that the loan amount shall not exceed $90,000, including the aggregate amount of all other previous loans between the lender and such a facility. Sets forth other requirements for loans to continuing care facilities.

Requires that a facility shall not be treated as a qualified continuing care facility unless substantially all facilities which are used to provide services under a continuing care contract are owned and operated by the borrower.

Provides that nursing homes are excluded from the definition of a qualified continuing care facility.

Provides for an inflation adjustment to the limit on the amount of the loans to qualified continuing care facilities for loans made during any calendar year after 1986.

Provides that the rate used for determining whether an employee relocation loan is a below-market loan to which additional interest will be imputed will be the AFR for the month in which the employee enters into a written contract for the purchase of a principal residence.

Provides that the imputed interest rules of the Code will not apply to payments made to an independent living facility for the elderly by a payor who is at least 65 years old if certain criteria are met.

Committees

The committees the bill was sent to, and what each did with it.

Data notes

A committee links to its page only where it exists in the current Congress; older and renamed committees are named without a link.

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Timeline

From introduction to signing, newest first: the committees, the floor and the president. 27 actions.

  1. Oct 11, 1985Became lawBecame law · Became Public Law No: 99-121.
  2. Became lawBecame law · Signed by President.
  3. Oct 3, 1985PresidentPresident · Presented to President.
  4. Oct 1, 1985Resolving differencesResolving differences · Senate agreed to conference report by Voice Vote.
  5. Resolving differencesResolving differences · Conference report agreed to in Senate: Senate agreed to conference report by Voice Vote.
  6. Resolving differencesResolving differences · Motion to postpone consideration of conference report not agreed to in Senate by Yea-Nay Vote. 07-91. Record Vote No: 199.Senate roll call 199
  7. Resolving differencesResolving differences · Conference report considered in Senate.
  8. Aug 1, 1985Resolving differencesResolving differences · House Agreed to Conference Report by Voice Vote.
  9. Resolving differencesResolving differences · Conference report agreed to in House: House Agreed to Conference Report by Voice Vote.
  10. Resolving differencesResolving differences · Conference Report 99-250 Filed in House.
  11. Resolving differencesResolving differences · Conference report filed: Conference Report 99-250 Filed in House.
  12. Resolving differencesResolving differences · Conferees agreed to file conference report.
  13. Resolving differencesResolving differences · Conference committee actions: Conferees agreed to file conference report.
  14. Resolving differencesResolving differences · House Agreed to Request for Conference and Speaker Appointed Conferees: Rostenkowski, Gibbons, Pickle, Rangel, Stark, Duncan, Archer, Vander Jagt.
  15. Resolving differencesResolving differences · House Disagreed to Senate Amendments by Unanimous Consent.
  16. Jun 26, 1985Resolving differencesResolving differences · Senate insists on its amendments, asks for a conference, appoints conferees Packwood; Roth; Chafee; Heinz; Durenberger; Long; Bentsen; Matsunaga; Moynihan.
  17. FloorFloor · Passed Senate with amendments by Voice Vote.
  18. FloorFloor · Motion to table The motion to waive the Budget Act with respect to sp428 agreed to in Senate by Yea-Nay Vote. 54-43. Record Vote No: 138.Senate roll call 138
  19. FloorFloor · Motion to proceed to consideration of measure agreed to in Senate.
  20. Jun 13, 1985CommitteeCommittee · Reported by Senate Finance Committee
  21. Jun 6, 1985CommitteeCommittee · Markup by Senate Finance Committee
  22. May 22, 1985CommitteeCommittee · Referred to Senate Finance Committee
  23. May 21, 1985FloorFloor · Passed House by Yea-Nay Vote: 425 - 0 (Record Vote No: 119).House roll call 119
  24. May 20, 1985CommitteeCommittee · Hearings by Energy, Natural Resources, and Infrastructure Subcommittee of the Senate Finance Committee
  25. May 14, 1985CommitteeCommittee · Reported by House Ways and Means Committee
  26. CommitteeCommittee · Referred to House Ways and Means Committee
  27. IntroducedIntroduced · Introduced in the House
Data notes

Shows the introduction, each committee and subcommittee step the source dates (referral, hearings, markup, report, discharge), and the floor, conference, presidential and became-law steps. Calendar placements, messages between the chambers, amendments and committee report numbers are not shown for laws before the 108th Congress. Two entries the source lists twice are shown once.

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Official record

The bill’s full text and every action, including introduction and committee steps, are on Congress.gov. Data through Oct 7, 2026.