rr-21-23.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. 2021-23

This revenue ruling provides various prescribed rates for federal income tax
purposes for December 2021 (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
sect ion 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.

REV. RUL. 2021-23 TABLE 1

2

Applicable Federal Rates (AFR) for December 2021

Period for Compounding
Annual Semiannual Quarterly Monthly

Short-term

AFR 0.33% 0.33% 0.33% 0.33%
110% AFR 0.36% 0.36% 0.36% 0.36%
120% AFR 0.40% 0.40% 0.40% 0.40%
130% AFR 0.43% 0.43% 0.43% 0.43%

Mid-term

AFR 1.26% 1.26% 1.26% 1.26%
110% AFR 1.39% 1.39% 1.39% 1.39%
120% AFR 1.52% 1.51% 1.51% 1.51%
130% AFR 1.65% 1.64% 1.64% 1.63%
150% AFR 1.90% 1.89% 1.89% 1.88%
175% AFR 2.22% 2.21% 2.20% 2.20%

Long-term

AFR 1.90% 1.89% 1.89% 1.88%
110% AFR 2.09% 2.08% 2.07% 2.07%
120% AFR 2.28% 2.27% 2.26% 2.26%
130% AFR 2.48% 2.46% 2.45% 2.45%

REV. RUL. 2021-23 TABLE 2

3
Adjusted AFR for December 2021

Period for Compounding
Annual Semiannual Quarterly Monthly
Short-term
adjusted AFR 0.25% 0.25% 0.25% 0.25%

Mid-term
adjusted AFR 0.96% 0.96% 0.96% 0.96%

Long-term
adjusted AFR 1.45% 1.44% 1.44% 1.44%

REV. RUL. 2021-23 TABLE 3

Rates Under Section 382 for December 2021

Adjusted federal long-term rate for the current month 1.45%

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.) 1.45%

REV. RUL. 2021-23 TABLE 4

Appropriate Percentages Under Section 42(b)(1) for December 2021
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 7.36%

Appropriate percentage for the 30% present value low-income
housing credit 3.15%

REV. RUL. 2021-23 TABLE 5

Rate Under Section 7520 for December 2021

4

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 1.6%