rr-25-05.pdf

us-irs-revenue-rulings-rr-25-05rr-25-05.pdfGuidance

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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. 2025-5

This revenue ruling provides various prescribed rates for federal income tax
purposes for February 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. 2025-5 TABLE 1

Applicable Federal Rates (AFR) for February 2025

Period for Compounding
Annual Semiannual Quarterly Monthly

Short-term

AFR 4.34% 4.29% 4.27% 4.25%
110% AFR 4.78% 4.72% 4.69% 4.67%
120% AFR 5.22% 5.15% 5.12% 5.10%
130% AFR 5.66% 5.58% 5.54% 5.52%

Mid-term

AFR 4.52% 4.47% 4.45% 4.43%
110% AFR 4.98% 4.92% 4.89% 4.87%
120% AFR 5.43% 5.36% 5.32% 5.30%
130% AFR 5.89% 5.81% 5.77% 5.74%
150% AFR 6.82% 6.71% 6.65% 6.62%
175% AFR 7.97% 7.82% 7.75% 7.70%

Long-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%

REV. RUL. 2025-5 TABLE 2

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Adjusted AFR for February 2025

Period for Compounding
Annual Semiannual Quarterly Monthly
Short-term
adjusted AFR 3.29% 3.26% 3.25% 3.24%

Mid-term
adjusted AFR 3.42% 3.39% 3.38% 3.37%

Long-term
adjusted AFR 3.67% 3.64% 3.62% 3.61%

REV. RUL. 2025-5 TABLE 3

Rates Under Section 382 for February 2025

Adjusted federal long-term rate for the current month 3.67%

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.) 3.67%

REV. RUL. 2025-5 TABLE 4

Appropriate Percentages Under Section 42(b)(1) for February 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 8.09%

Appropriate percentage for the 30% present value low-income
housing credit 3.47%

REV. RUL. 2025-5 TABLE 5

Rate Under Section 7520 for February 2025

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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 5.4%

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