rr-23-05.pdf

us-irs-revenue-rulings-rr-23-05rr-23-05.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. 2023-5

This revenue ruling provides various prescribed rates for federal income tax
purposes for March 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
secti on 1 274(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 a nd 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, unde r 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. 2023-5 TABLE 1

Applicable Federal Rates (AFR) for March 2023

Period for Compounding
Annual Semiannual Quarterly Monthly

Short-term

AFR 4.50% 4.45% 4.43% 4.41%
110% AFR 4.96% 4.90% 4.87% 4.85%
120% AFR 5.41% 5.34% 5. 30% 5.28%
130% AFR 5.87% 5.79% 5.75% 5.72%

Mid-term

AFR 3.70% 3.67% 3.65% 3.64%
110% AFR 4.08% 4.04% 4.02% 4.01%
120% AFR 4.45% 4.40% 4.38% 4.36%
130% AFR 4.83% 4.77% 4.74% 4.72%
150% AFR 5.59% 5.51% 5.47% 5.45%
175% AFR 6.52% 6.42% 6.37% 6.34%

Long-term

AFR 3.74% 3.71% 3.69% 3.68%
110% AFR 4.12% 4.08% 4.06% 4.05%
120% AFR 4.50% 4.45% 4.43% 4.41%
130% AFR 4.88% 4.82% 4.79% 4.77%

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REV. RUL. 2023-5 TABLE 2

Adjusted AFR for March 2023

Period for Compounding
Annual Semiannual Quarterly Monthly
Short-term
adjusted AFR 3.41% 3.38% 3.37% 3.36%

Mid-term
adjusted AFR 2.81% 2.79% 2.78% 2.77%

Long-term
adjusted AFR 2.84% 2.82% 2.81% 2.80%

REV. RUL. 2023-5 TABLE 3

Rates Under Section 382 for March 2023

Adjusted federal l ong-term rate for the current month 2.84%

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.) 2.92%

REV. RUL. 2023-5 TABLE 4

Appropriate Percentages Under Section 42(b)(1) for March 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 percenta ge for the 70% present value low-income
housing credit 7.86%

Appropriate percentage for the 30% present value low-income
housing credit 3.37%

REV. RUL. 2023-5 TABLE 5

4

Rate Under Section 7520 for March 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 4.40%

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