rr-25-10.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. 2025-10

This revenue ruling provides various prescribed rates for federal income tax
purposes for May 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. 2025-10 TABLE 1

Applicable Federal Rates (AFR) for May 2025

Period for Compounding
Annual Semiannual Quarterly Monthly

Short-term

AFR 4.05% 4.01% 3.99% 3.98%
110% AFR 4.46% 4.41% 4.39% 4.37%
120% AFR 4.87% 4.81% 4.78% 4.76%
130% AFR 5.28% 5.21% 5.18% 5.15%

Mid-term

AFR 4.10% 4.06% 4.04% 4.03%
110% AFR 4.52% 4.47% 4.45% 4.43%
120% AFR 4.93% 4.87% 4.84% 4.82%
130% AFR 5.35% 5.28% 5.25% 5.22%
150% AFR 6.18% 6.09% 6.04% 6.01%
175% AFR 7.24% 7.11% 7.05% 7.01%

Long-term

AFR 4.62% 4.57% 4.54% 4.53%
110% AFR 5.09% 5.03% 5.00% 4.98%
120% AFR 5.56% 5.48% 5.44% 5.42%
130% AFR 6.03% 5.94% 5.90% 5.87%

REV. RUL. 2025-10 TABLE 2

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Adjusted AFR for May 2025

Period for Compounding
Annual Semiannual Quarterly Monthly
Short-term
adjusted AFR 3.06% 3.04% 3.03% 3.02%

Mid-term
adjusted AFR 3.10% 3.08% 3.07% 3.06%

Long-term
adjusted AFR 3.50% 3.47% 3.46% 3.45%

REV. RUL. 2025-10 TABLE 3

Rates Under Section 382 for May 2025

Adjusted federal long-term rate for the current month 3.50%

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.) 3.64%

REV. RUL. 2025-10 TABLE 4

Appropriate Percentages Under Section 42(b)(1) for May 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 8.01%

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

REV. RUL. 2025-10 TABLE 5

Rate Under Section 7520 for May 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%