The 2020 editions erroneously describe the regular corporate interest rate (2% above the federal rate) as the "GATT" rate. The special reduced rate (.5% above the federal rate or 1.5% lower than the regular corporate overpayment rate) is the GATT rate. The following are the corrections to paragraph III.B.2. subparagraphs a. and b.).
a. General 1% Reduction.
For corporations, however, the overpayment interest rate is reduced by one percent (i.e., the rate is the short-term federal rate plus 2 percent rather than 3 percent). § 6621(a)(1). For the third quarter of 2020, this interest rate is 2%.
b. Reduction for Corporate Overpayments Over $10,000.
There is a critical exception–for corporate overpayments exceeding $10,000–the short-term federal rate is only increased by 0.5 percentage points. § 6621(a)(1) (flush language). (This reduced interest rate is often referred to as the “GATT rate”). Mathematically, the interest rate is 1.5% lower than the regular corporate rate discussed above. For the third quarter of 2020, this interest rate is 0.5 %.
As you can see, this low interest rate is a powerful incentive for corporations not to loan money to the Government via overpayment of taxes, because they can likely achieve a better return elsewhere. (By the same token, of course, as noted above, the large corporate underpayment interest premium–the so-called “hot interest” in § 6621(c)–creates a powerful incentive to avoid being a debtor to the Government at least after the IRS makes the critical determinations of additional tax due and owing; in short, there are incentives for corporations to better manage the due tos and due froms in the tax area.) Although S Corporations are normally not subject to tax, sometimes they can be; the court opinions conflict as to whether any overpayment by S Corporations will be subject to this reduced interest rate. This reduction is also applied to any amounts due by the Government that are treated as a tax for purposes of calculating interest on the amounts due, such as, for example, interest due on wrongful levies.
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