rr-25-06.pdf

us-irs-revenue-rulings-rr-25-06rr-25-06.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. 2025-6

This revenue ruling provides various prescribed rates for federal income tax
purposes for March 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. 2025-6 TABLE 1

Applicable Federal Rates (AFR) for March 2025

Period for Compounding
Annual Semiannual Quarterly Monthly

Short-term

AFR 4.31% 4.26% 4.24% 4.22%
110% AFR 4.74% 4.69% 4.66% 4.64%
120% AFR 5.18% 5.11% 5.08% 5.06%
130% AFR 5.62% 5.54% 5.50% 5.48%

Mid-term

AFR 4.46% 4.41% 4.39% 4.37%
110% AFR 4.91% 4.85% 4.82% 4.80%
120% AFR 5.36% 5.29% 5.26% 5.23%
130% AFR 5.81% 5.73% 5.69% 5.66%
150% AFR 6.73% 6.62% 6.57% 6.53%
175% AFR 7.87% 7.72% 7.65% 7.60%

Long-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%

REV. RUL. 2025-6 TABLE 2

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Adjusted AFR for March 2025

Period for Compounding
Annual Semiannual Quarterly Monthly
Short-term
adjusted AFR 3.26% 3.23% 3.22% 3.21%

Mid-term
adjusted AFR 3.38% 3.35% 3.34% 3.33%

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

REV. RUL. 2025-6 TABLE 3

Rates Under Section 382 for March 2025

Adjusted federal long-term rate for the current month 3.64%

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. 2025-6 TABLE 4

Appropriate Percentages Under Section 42(b)(1) for March 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 8.08%

Appropriate percentage for the 30% present value low-income
housing credit 3.46%

REV. RUL. 2025-6 TABLE 5

Rate Under Section 7520 for March 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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