rr-23-21.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. 2023-21

This revenue ruling provides various prescribed rates for federal income tax
purposes for December 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. 2023-21 TABLE 1

Applicable Federal Rates (AFR) for December 2023

Period for Compounding
Annual Semiannual Quarte rly Monthly

Short-term

AFR 5.26% 5.19% 5.16% 5.13%
110% AFR 5.79% 5.71% 5.67% 5.64%
120% AFR 6.33 % 6.23% 6.18% 6.15%
130% AFR 6.86% 6.75% 6.69% 6.66%

Mid-term

AFR 4.82% 4.76% 4.73% 4.71%
110% AFR 5.31% 5.24% 5.21% 5.18%
120% AFR 5.79% 5.71% 5.67% 5.64%
130% AFR 6.29% 6.19% 6.14% 6.11%
15 0% AFR 7.27% 7.14% 7.08% 7.04%
175% AFR 8.50% 8.33% 8.25% 8.19%

Long-term

AFR 5.03% 4.97% 4.94% 4.92 %
110% AFR 5.54% 5.47% 5.43% 5.41%
12 0% AFR 6.05% 5.96% 5.92% 5.89%
130% AFR 6.56% 6.46% 6.41% 6.37%

REV. RUL. 2023-21 TABLE 2

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Adjusted AFR for December 2023

Period for Compounding
Annual Semia nnual Quarterly Monthly
Short-term
adjusted AFR 3.98% 3.94% 3.92% 3.91%

Mid-term
adjusted AFR 3.64% 3.61% 3.59 % 3.58%

Long-term
adjusted AFR 3.81% 3.77% 3.75% 3.74%

REV. RUL. 2023-21 TABLE 3

Rates Under Section 382 for December 2023

Adjusted federal long-term rate for the current month 3.81%

Long-term tax-exempt rate for ownership changes during the
current month (the highest of the adjusted federal long-term
rates for the current mon th and the prior two months.) 3.81%

REV. RUL. 2023-21 TABLE 4

Appropriat e Percentages Under Section 42(b)(1) for December 2023
Note: Under section 42(b)(2), the applicable percentage for non-federally subsidized
new buildings placed in service after Jul y 30, 2008, shall not be less than 9%.

Appropriate percentage for t he 70% present value low-income
housing credit 8.15%

Appropriate percentage for the 30% present value low-income
housing credit 3.49%

REV. RUL. 2023-21 TABLE 5

Rate Under Section 7520 for December 2023

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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 5.80%