rr-25-21.pdf

us-irs-revenue-rulings-rr-25-21rr-25-21.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. 2025-21

This revenue ruling provides various prescribed rates for federal income tax
purposes for November 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. 2025-21 TABLE 1

Applicable Federal Rates (AFR) for November 2025

Period for Compounding
Annual Semiannual Quarterly Monthly

Short-term

AFR 3.69% 3.66% 3.64% 3.63%
110% AFR 4.07% 4.03% 4.01% 4.00%
120% AFR 4.44% 4.39% 4.37% 4.35%
130% AFR 4.82% 4.76% 4.73% 4.71%

Mid-term

AFR 3.83% 3.79% 3.77% 3.76%
110% AFR 4.21% 4.17% 4.15% 4.13%
120% AFR 4.60% 4.55% 4.52% 4.51%
130% AFR 4.99% 4.93% 4.90% 4.88%
150% AFR 5.77% 5.69% 5.65% 5.62%
175% AFR 6.74% 6.63% 6.58% 6.54%

Long-term

AFR 4.62% 4.57% 4.54% 4.53%
110% AFR 5.09% 5.03% 5.00% 4.98%
120% AFR 5.56% 5.48% 5.44% 5.42%
130% AFR 6.03% 5.94% 5.90% 5.87%

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REV. RUL. 2025-21 TABLE 2

Adjusted AFR for November 2025

Period for Compounding
Annual Semiannual Quarterly Monthly
Short-term
adjusted AFR 2.80% 2.78% 2.77% 2.76%

Mid-term
adjusted AFR 2.90% 2.88% 2.87% 2.86%

Long-term
adjusted AFR 3.50% 3.47% 3.46% 3.45%

REV. RUL. 2025-21 TABLE 3

Rates Under Section 382 for November 2025

Adjusted federal long-term rate for the current month 3.50%

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.) 3.65%

REV. RUL. 2025-21 TABLE 4

Appropriate Percentages Under Section 42(b)(1) for November 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 7.98%

Appropriate percentage for the 30% present value low-income
housing credit 3.42%

REV. RUL. 2025-21 TABLE 5

4

Rate Under Section 7520 for November 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%

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