rr-25-19.pdf

us-irs-revenue-rulings-rr-25-19rr-25-19.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. 2025-19

This revenue ruling provides various prescribed rates for federal income tax
purposes for October 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. 2025-19 TABLE 1

Applicable Federal Rates (AFR) for October 2025

Period for Compounding
Annual Semiannual Quarterly Monthly

Short-term

AFR 3.81% 3.77% 3.75% 3.74%
110% AFR 4.19% 4.15% 4.13% 4.11%
120% AFR 4.57% 4.52% 4.49% 4.48%
130% AFR 4.96% 4.90% 4.87% 4.85%

Mid-term

AFR 3.87% 3.83% 3.81% 3.80%
110% AFR 4.25% 4.21% 4.19% 4.17%
120% AFR 4.65% 4.60% 4.57% 4.56%
130% AFR 5.04% 4.98% 4.95% 4.93%
150% AFR 5.83% 5.75% 5.71% 5.68%
175% AFR 6.81% 6.70% 6.64% 6.61%

Long-term

AFR 4.73% 4.68% 4.65% 4.64%
110% AFR 5.22% 5.15% 5.12% 5.10%
120% AFR 5.70% 5.62% 5.58% 5.56%
130% AFR 6.17% 6.08% 6.03% 6.00%

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REV. RUL. 2025-19 TABLE 2

Adjusted AFR for October 2025

Period for Compounding
Annual Semiannual Quarterly Monthly
Short-term
adjusted AFR 2.88% 2.86% 2.85% 2.84%

Mid-term
adjusted AFR 2.93% 2.91% 2.90% 2.89%

Long-term
adjusted AFR 3.58% 3.55% 3.53% 3.52%

REV. RUL. 2025-19 TABLE 3

Rates Under Section 382 for October 2025

Adjusted federal long-term rate for the current month 3.58%

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.) 3.65%

REV. RUL. 2025-19 TABLE 4

Appropriate Percentages Under Section 42(b)(1) for October 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 8.00%

Appropriate percentage for the 30% present value low-income
housing credit 3.43%

REV. RUL. 2025-19 TABLE 5

4

Rate Under Section 7520 for October 2025

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 4.6%

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