rr-23-20.pdf

us-irs-revenue-rulings-rr-23-20rr-23-20.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. 2023-20

This revenue ruling provides various prescribed rates for federal income tax
purposes for November 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. 2023-20 TABLE 1

Applicable Federal Rates (AFR) for November 2023

Period for Compounding
Annual Semiannual Quarte rly Monthly

Short-term

AFR 5.30% 5.23% 5.20% 5.17%
110% AFR 5.83% 5.75% 5.71% 5.68%
120% AFR 6.38% 6.28% 6.23 % 6.20%
130% AFR 6.92% 6.80% 6.74 % 6.71%

Mid-term

AFR 4.69% 4.64% 4.61% 4.60%
110% AFR 5.17% 5.10% 5.07% 5.05%
120% AFR 5.65% 5.57% 5.53% 5.51%
130% AFR 6.12% 6.03% 5.99% 5.96%
150% AFR 7.08% 6.96% 6.90% 6.86%
175% AFR 8.28% 8.12% 8.04% 7.99%

Long-t
erm

AFR 4.83% 4.77% 4.74% 4.72%
110% AFR 5.32% 5.25% 5.22% 5.19%
120% AFR 5.80% 5.72% 5.68% 5.65%
130% AFR 6.30% 6.20% 6.15% 6.12%

RE
V. RUL. 2023-20 TABLE 2

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Adjusted AFR for November 2023

Period for Compounding
Annual Semia nnual Quarterly Monthly
Short-term
adjusted AFR 4.01% 3.97% 3.95% 3.94%

Mid-term
adjusted AFR 3.55% 3.52% 3.50% 3.49%

Long-term
adjusted AFR 3.65% 3.62% 3.60% 3.59%

RE
V. RUL. 2023-20 TABLE 3

Rates Under Section 382 for November 2023

Adjusted federal long-term rate for the current month 3.65%

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. 2023- 20 TABLE 4

Appropriat e Percentages Under Section 42(b)(1) for November 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 8.11%

Appropriate percentage for the 30% present value low-income
housing credit 3.47%

REV. RUL. 2023-20 TABLE 5

Rate Under Section 7520 for November 2023

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Applicable federal r ate for determining the present value of an
annuity, an interest for life or a term of years, or a remainder or
reversionary interest 5.60%

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