rr-23-12.pdf

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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. 2023-12

This revenue ruling provides various prescribed rates for federal income tax
purposes for July 2023 (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%. 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. Finally, Table 6 contains the blended annual rate for 2023 for purposes of
section 7872.

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REV. RUL. 2023-12 TABLE 1

Applicable Federal Rates (AFR) for July 2023

Period for Compounding
Annual Semiannual Quarterly Monthly

Short-term

AFR 4.80% 4.74% 4.71% 4.69%
110% AFR 5.28% 5.21% 5.18% 5.15%
120% AFR 5.77% 5.69% 5.65% 5.62%
130% AFR 6.25% 6.16% 6.11% 6.08%

Mid-term

AFR 3.85% 3.81% 3.79% 3.78%
110% AFR 4.23% 4.19% 4.17% 4.15%
120% AFR 4.62% 4.57% 4.54% 4.53%
130% AFR 5.01% 4.95% 4.92% 4.90%
150% AFR 5.80% 5.72% 5.68% 5.65%
175% AFR 6.78% 6.67% 6.62% 6.58%

Long-term

AFR 3.98% 3.94% 3.92% 3.91%
110% AFR 4.38% 4.33% 4.31% 4.29%
120% AFR 4.79% 4.73% 4.70% 4.68%
130% AFR 5.19% 5.12% 5.09% 5.07%

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REV. RUL. 2023-12 TABLE 2

Adjusted AFR for July 2023

Period for Compounding
Annual Semiannual Quarterly Monthly
Short-term
adjusted AFR 3.63% 3.60% 3.58% 3.57%

Mid-term
adjusted AFR 2.91% 2.89% 2.88% 2.87%

Long-term
adjusted AFR 3.01% 2.99% 2.98% 2.97%

REV. RUL. 2023-12 TABLE 3

Rates Under Section 382 for July 2023

Adjusted federal long-term rate for the current month 3.01%

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.) 3.01%

REV. RUL. 2023-12 TABLE 4

Appropriate Percentages Under Section 42(b)(1) for July 2023
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 7.91%

Appropriate percentage for the 30% present value low-income
housing credit 3.39%

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REV. RUL. 2023-12 TABLE 5

Rate Under Section 7520 for July 2023

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 4.60%

REV. RUL. 2023-12 TABLE 6

Blended Annual Rate for 2023

Section 7872(e)(2) blended annual rate for 2023 4.65%