(b) Federal short-term rate For purposes of this section—
(1) General rule
The Secretary shall determine the Federal short-term rate for the first month in each calendar quarter.
(2) Period during which rate applies
(A) In general
Except as provided in subparagraph (B), the Federal short-term rate determined under paragraph (1) for any month shall apply during the first calendar quarter beginning after such month.
(3) Federal short-term rate
The Federal short-term rate for any month shall be the Federal short-term rate determined during such month by the Secretary in accordance with section 1274(d).
and IRC 1274(d)(1)(B) https://www.law.cornell.edu/uscode/text/26/1274 says:
(B) Determination of rates
During each calendar month, the Secretary shall determine the Federal short-term rate, mid-term rate, and long-term rate which shall apply during the following calendar month.
Questions:
[1] So "The Federal short-term rate for any month = the Federal short-term rate determined during such month = "the Federal short-term rate applied for the following calendar month"?
Is this the standard use of the word "for"? If we say "rate for a month", doesn't it means the rate applicable for the month?
[2] When we look up the the Federal short-term rate for a given month from https://apps.irs.gov/app/picklist/list/federalRates.html, it is the rate determined during or applied for the month?
[3] "the Federal short-term rate determined under paragraph (1) for any month shall apply during the first calendar quarter beginning after such month", so if we need to determine the underpayment rate as defined in IRC 6621(a)(2) for the 4th quarter, we should look up the Federal short-term rate applied for August? i.e. underpayment rate as defined in IRC 6621(a)(2) = the Federal short-term rate determined during the first month and applied for the second month of the previous quarter, rounded up to nearest integer, and plus 3%?
Each month in the quarter has its own monthly short-term rate, but we ignore that for the purpose of determine the underpayment rate as defined in IRC 6621(a)(2), but use the rate applied for the second month of the previous quarter?
[4] The two statements seem to be inconsistent:
- "The Secretary shall determine the Federal short-term rate for the first month in each calendar quarter"
"During each calendar month, the Secretary shall determine the Federal short-term rate".
The first statement seems to indicate the secretary only determine the rate for the first month in each quarter.