DETERMINATION OF ISSUE PRICE IN THE CASE OF CERTAIN DEBT INSTRUMENTS ISSUED FOR PROPERTY:
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. 2023-18
This revenue ruling provides various prescribed rates for federal income tax purposes for October 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.
REV. RUL. 2023-18 TABLE 1
Applicable Federal Rates (AFR) for October 2023
Period for Compounding
| Annual | Semiannual | Quarterly | Monthly | |
|---|---|---|---|---|
|
Short-term |
||||
| AFR | 5.22% | 5.15% | 5.12% | 5.10% |
| 110% AFR | 5.75% | 5.67% | 5.63% | 5.60% |
| 120% AFR | 6.28% | 6.18% | 6.13% | 6.10% |
|
Mid-term |
||||
| AFR | 4.43% | 4.38% | 4.36% | 4.34% |
| 110% AFR | 4.88% | 4.82% | 4.79% | 4.77% |
| 120% AFR | 5.33% | 5.26% | 5.23% | 5.20% |
| 130% AFR | 5.77% | 5.69% | 5.65% | 5.62% |
| 150% AFR | 6.68% | 6.57% | 6.52% | 6.48% |
| 175% AFR | 7.82% | 7.67% | 7.60% | 7.55% |
|
Long-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% | 4.23% |
| 130% AFR | 5.81% | 5.73% | 5.69% | 5.66% |
REV. RUL. 2023-18 TABLE 2
Adjusted AFR for October 2023
Period for Compounding
| Annual | Semiannual | Quarterly | Monthly | |
|---|---|---|---|---|
|
Short-term adjusted AFR |
3.95% | 3.91% | 3.89% | 3.88% |
|
Mid-term adjusted AFR |
3.36% | 3.33% | 3.32% | 3.31% |
|
Long-term adjusted AFR |
3.38% | 3.35% | 3.34% | 3.33% |
REV. RUL. 2023-18 TABLE 3
Rates Under Section 382 for October 2023
| Adjusted federal long-term rate for the current month | 3.38% |
|
Long-term tax-exempt rate for ownership changes during the current month |
3.38% |
REV. RUL. 2023-18 TABLE 4
Appropriate Percentages Under Section 42(b)(1) for October 2023
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%.
|
Applicable federal rate for determining the present value of an annuity, an interest |
5.40% |
