rr-25-24.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. 2025-24

This revenue ruling provides various prescribed rates for federal income tax
purposes for December 2025 (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. 2025-24 TABLE 1

Applicable Federal Rates (AFR) for December 2025

Period for Compounding
Annual Semiannual Quarterly Monthly

Short-term

AFR 3.66% 3.63% 3.61% 3.60%
110% AFR 4.03% 3.99% 3.97% 3.96%
120% AFR 4.41% 4.36% 4.34% 4.32%
130% AFR 4.78% 4.72% 4.69% 4.67%

Mid-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%
150% AFR 5.71% 5.63% 5.59% 5.57%
175% AFR 6.67% 6.56% 6.51% 6.47%

Long-term

AFR 4.55% 4.50% 4.47% 4.46%
110% AFR 5.01% 4.95% 4.92% 4.90%
120% AFR 5.47% 5.40% 5.36% 5.34%
130% AFR 5.94% 5.85% 5.81% 5.78%

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REV. RUL. 2025-24 TABLE 2

Adjusted AFR for December 2025

Period for Compounding
Annual Semiannual Quarterly Monthly
Short-term
adjusted AFR 2.78% 2.76% 2.75% 2.74%

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

Long-term
adjusted AFR 3.45% 3.42% 3.41% 3.40%

REV. RUL. 2025-24 TABLE 3

Rates Under Section 382 for December 2025

Adjusted federal long-term rate for the current month 3.45%

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.) 3.58%

REV. RUL. 2025-24 TABLE 4

Appropriate Percentages Under Section 42(b)(1) for December 2025
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 7.97%

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

REV. RUL. 2025-24 TABLE 5

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Rate Under Section 7520 for December 2025

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 4.60%