rr-23-10.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. 2023-10

This revenue ruling provides various prescribed rates for federal income tax
purposes for June 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. 2023-10 TABLE 1

Applicable Federal Rates (AFR) for June 2023

Period for Compounding
Annual Semiannual Quarterly Monthly

Short-term

AFR 4.43% 4.38% 4.36% 4.34%
110% AFR 4.88% 4.82% 4.79% 4.77%
120% AFR 5.33% 5.26% 5.23% 5.20%
130% AFR 5.77% 5.69% 5.65% 5.62%

Mid-term

AFR 3.56% 3.53% 3.51% 3.50%
110% AFR 3.92% 3.88% 3.86% 3.85%
120% AFR 4.28% 4.24% 4.22% 4.20%
130% AFR 4.64% 4.59% 4.56% 4.55%
150% AFR 5.37% 5.30% 5.27% 5.24%
175% AFR 6.28% 6.18% 6.13% 6.10%

Long-term

AFR 3.79% 3.75% 3.73% 3.72%
110% AFR 4.17% 4.13% 4.11% 4.09%
120% AFR 4.55% 4.50% 4.47% 4.46%
130% AFR 4.94% 4.88% 4.85% 4.83%

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REV. RUL. 2023-10 TABLE 2

Adjusted AFR for June 2023

Period for Compounding
Annual Semiannual Quarterly Monthly
Short-term
adjusted AFR 3.36% 3.33% 3.32% 3.31%

Mid-term
adjusted AFR 2.70% 2.68% 2.67% 2.67%

Long-term
adjusted AFR 2.87% 2.85% 2.84% 2.83%

REV. RUL. 2023-10 TABLE 3

Rates Under Section 382 for June 2023

Adjusted federal long-term rate for the current month 2.87%

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. 2023-10 TABLE 4

Appropriate Percentages Under Section 42(b)(1) for June 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 percentage for the 70% present value low-income
housing credit 7.85%

Appropriate percentage for the 30% present value low-income
housing credit 3.36%

REV. RUL. 2023-10 TABLE 5

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Rate Under Section 7520 for June 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 4.20%