rr-23-18.pdf

us-irs-revenue-rulings-rr-23-18rr-23-18.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. 2023-18

This revenue ruling provides various prescribed rates for federal income tax
purposes for October 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%. 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. 2023-18 TABLE 1

Applicable Federal Rates (AFR) for October 2023

Period for Compounding
Annual Semiannual Quarte rly Monthly

Short-term

AFR 5.22% 5.15% 5.12% 5.10%
110% AFR 5.75% 5.67% 5.63 % 5.60%
120% AFR 6.28% 6.18% 6.13% 6.10%
130% AFR 6.81% 6.70% 6.64% 6.61%

Mid-term

AFR 4.43% 4.38% 4.36 % 4.34%
110% AFR 4.88% 4.82% 4.79% 4.77%
120% AFR 5.33% 5.26% 5.23% 5.20%
130% AFR 5.77% 5.69% 5.65% 5.62%
15 0% AFR 6.68% 6.57% 6.52% 6.48%
175% AFR 7.82% 7.67% 7.60% 7.55%

Long-term

AFR 4.46% 4.41% 4.39% 4.37%
110% AFR 4.91% 4.85% 4.82% 4.80%
12 0% AFR 5.36% 5.29% 5.26% 5.23%
130% AFR 5.81% 5.73% 5.69% 5.66%

REV. RUL. 2023-18 TABLE 2

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Adjusted AFR for October 2023

Period for Compounding
Annual Semia nnual Quarterly Monthly
Short-term
adjusted AFR 3.95% 3.91% 3.89% 3.88%

Mid-term
adjusted AFR 3.36% 3.33% 3.32% 3.31%

Long-term
adjusted AFR 3.38% 3.35% 3.34 % 3.33%

REV. RUL. 2023-18 TABLE 3

Rates Under Section 382 for October 2023

Adjusted federal long-term rate for the current month 3.38%

Long-term tax-exempt rate for ownership changes during the
current month (the highest of the adjusted federal long-term
rates for the current mon th and the prior two months.) 3.38%

REV. RUL. 2023-18 TABLE 4

Appropriat e Percentages Under Section 42(b)(1) for October 2023
Note: Under section 42(b)(2), the applicable percentage for non-federally subsidized
new buildings placed in service after Jul y 30, 2008, shall not be less than 9%.

Appropriate percentage for t he 70% present value low-income
housing credit 8.03%

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

REV. RUL. 2023-18 TABLE 5

Rate Under Section 7520 for October 2023

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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 5.40%

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