rr-23-06.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. 2023-6

This revenue ruling provides various prescribed rates for federal income tax
purposes for April 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. 2023-6 TABLE 1

Applicable Federal Rates (AFR) for April 2023

Period for Compounding
Annual Semiannual Quarterly Monthly

Short-term

AFR 4.86% 4.80% 4.77% 4.75%
110% AFR 5.35% 5.28% 5.25% 5.22%
120% AFR 5.84% 5.76% 5. 72% 5. 69%
130% AFR 6.34% 6.24% 6.19% 6.16%

Mid-term

AFR 4.15% 4.11% 4.09% 4.08%
110% AFR 4.57% 4.52% 4.49% 4.48%
120% AFR 4.99% 4.93% 4.90% 4.88%
130% AFR 5.41% 5.34% 5.30% 5.28%
150% AFR 6.27% 6.17% 6.12% 6.09%
175% AFR 7.32% 7.19% 7.13% 7.08%

Long-term

AFR 4.02% 3.98% 3.96% 3.95%
110% AFR 4.43% 4.38% 4.36% 4.34%
120% AFR 4.84% 4.78% 4.75% 4.73%
130% AFR 5.24% 5.17% 5.14% 5.12%

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REV. RUL. 2023-6 TABLE 2

Adjusted AFR for April 2023

Period for Compounding
Annual Semiannual Quarterly Monthly
Short-term
adjusted AFR 3.67% 3.64% 3.62% 3.61%

Mid-term
adjusted AFR 3.14% 3.12% 3.11% 3.10%

Long-term
adjusted AFR 3.04% 3.02% 3.01% 3.00%

REV. RUL. 2023-6 TABLE 3

Rates Under Section 382 for April 2023

Adjusted federal l ong-term rate for the current month 3.04%

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.) 3.04%

REV. RUL. 2023-6 TABLE 4

Appropriate Percentages Under Section 42(b)(1) for April 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 7.95%

Appropriate percentage for the 30% present value low-income
housing credit 3.41%

REV. RUL. 2023-6 TABLE 5

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Rate Under Section 7520 for April 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 5.00%