rr-25-08.pdf

us-irs-revenue-rulings-rr-25-08rr-25-08.pdfGuidance

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Section 1274.--Determination of Issue Price in the Case of Certain Debt Instruments
Issued for Property

(Also Sections 42, 280G, 382, 467, 468, 482, 483, 1288, 7520, 7872.)

Rev. Rul. 2025-8

This revenue ruling provides various prescribed rates for federal income tax
purposes for April 2025 (the current month). Table 1 contains the short-term, mid-term,
and long-term applicable federal rates (AFR) for the current month for purposes of
section 1274(d) of the Internal Revenue Code. Table 2 contains the short-term, mid-
term, and long-term adjusted applicable federal rates (adjusted AFR) for the current
month for purposes of section 1288(b). Table 3 sets forth the adjusted federal long-
term rate and the long-term tax-exempt rate described in section 382(f). Table 4
contains the appropriate percentages for determining the low-income housing credit
described in section 42(b)(1) for buildings placed in service during the current month.
However, under section 42(b)(2), the applicable percentage for non-federally subsidized
new buildings placed in service after July 30, 2008, shall not be less than 9%. Finally,
Table 5 contains the federal rate for determining the present value of an annuity, an
interest for life or for a term of years, or a remainder or a reversionary interest for
purposes of section 7520.

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REV. RUL. 2025-8 TABLE 1

Applicable Federal Rates (AFR) for April 2025

Period for Compounding
Annual Semiannual Quarterly Monthly

Short-term

AFR 4.16% 4.12% 4.10% 4.09%
110% AFR 4.58% 4.53% 4.50% 4.49%
120% AFR 5.00% 4.94% 4.91% 4.89%
130% AFR 5.43% 5.36% 5.32% 5.30%

Mid-term

AFR 4.21% 4.17% 4.15% 4.13%
110% AFR 4.64% 4.59% 4.56% 4.55%
120% AFR 5.06% 5.00% 4.97% 4.95%
130% AFR 5.49% 5.42% 5.38% 5.36%
150% AFR 6.36% 6.26% 6.21% 6.18%
175% AFR 7.43% 7.30% 7.23% 7.19%

Long-term

AFR 4.61% 4.56% 4.53% 4.52%
110% AFR 5.08% 5.02% 4.99% 4.97%
120% AFR 5.54% 5.47% 5.43% 5.41%
130% AFR 6.02% 5.93% 5.89% 5.86%

REV. RUL. 2025-8 TABLE 2

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Adjusted AFR for April 2025

Period for Compounding
Annual Semiannual Quarterly Monthly
Short-term
adjusted AFR 3.15% 3.13% 3.12% 3.11%

Mid-term
adjusted AFR 3.20% 3.17% 3.16% 3.15%

Long-term
adjusted AFR 3.49% 3.46% 3.45% 3.44%

REV. RUL. 2025-8 TABLE 3

Rates Under Section 382 for April 2025

Adjusted federal long-term rate for the current month 3.49%

Long-term tax-exempt rate for ownership changes during the
current month (the highest of the adjusted federal long-term
rates for the current month and the prior two months.) 3.67%

REV. RUL. 2025-8 TABLE 4

Appropriate Percentages Under Section 42(b)(1) for April 2025
Note: Under section 42(b)(2), the applicable percentage for non-federally subsidized
new buildings placed in service after July 30, 2008, shall not be less than 9%.

Appropriate percentage for the 70% present value low-income
housing credit 8.02%

Appropriate percentage for the 30% present value low-income
housing credit 3.44%

REV. RUL. 2025-8 TABLE 5

Rate Under Section 7520 for April 2025

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Applicable federal rate for determining the present value of an
annuity, an interest for life or a term of years, or a remainder or
reversionary interest 5.00%

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