applicable rate

(2) Applicable rate The term “applicable rate” means— (A) the applicable Federal rate determined under section 1274(d) (compounded semiannually) as if the conversion transaction were a debt instrument, or (B) if the term of the conversion transaction is indefinite, the Federal short-term rates in effect under section 6621(b) during the period of the conversion transaction (compounded daily).


26 USC § 1258(d)(2)

Scoping language

None identified. Default scope is assumed to be the entire title.
Is this correct? or