Internal Revenue Bulletin — Rulings & Guidance
Rev. Rul. 2023-6 — Federal rates; adjusted federal rates; adjusted federal long-term rate, and the long-term tax exempt rate.
This revenue ruling provides various prescribed rates for federal income tax purposes for April 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. 2023-6 TABLE 1 Applicable Federal Rates (AFR) for April 2023 Period for Compounding
| Annual | Semiannual | Quarterly | Monthly | |
|---|---|---|---|---|
| Short-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% |
| Mid-term | ||||
| AFR | 4.15% | 4.11% | 4.09% | 4.08% |
| 110% AFR | 4.57% | 4.52% | 4.49% | 4.48% |
| 120% AFR | 4.99% | 4.93% | 4.90% | 4.88% |
| 130% AFR | 5.41% | 5.34% | 5.30% | 5.28% |
| 150% AFR | 6.27% | 6.17% | 6.12% | 6.09% |
| 175% AFR | 7.32% | 7.19% | 7.13% | 7.08% |
| Long-term | ||||
| AFR | 4.02% | 3.98% | 3.96% | 3.95% |
| 110% AFR | 4.43% | 4.38% | 4.36% | 4.34% |
| 120% AFR | 4.84% | 4.78% | 4.75% | 4.73% |
| 130% AFR | 5.24% | 5.17% | 5.14% | 5.12% |
REV. RUL. 2023-6 TABLE 2 Adjusted AFR for April 2023 Period for Compounding
| Annual | Semiannual | Quarterly | Monthly | |
|---|---|---|---|---|
| Short-term adjusted AFR | 3.67% | 3.64% | 3.62% | 3.61% |
| Mid-term adjusted AFR | 3.14% | 3.12% | 3.11% | 3.10% |
| Long-term adjusted AFR | 3.04% | 3.02% | 3.01% | 3.00% |
REV. RUL. 2023-6 TABLE 3 Rates Under Section 382 for April 2023
| Adjusted federal long-term rate for the current month | 3.04% |
| 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.) | 3.04% |
REV. RUL. 2023-6 TABLE 4 Appropriate Percentages Under Section 42(b)(1) for April 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%. | |
| Appropriate percentage for the 70% present value low-income housing credit | 7.95% |
| Appropriate percentage for the 30% present value low-income housing credit | 3.41% |
Section 42.—Low-Income Housing Credit
The applicable federal short-term, mid-term, and long-term rates are set forth for the month of April 2023. See Rev. Rul. 2023-6, page 627.
Section 280G.—Golden Parachute Payments
The applicable federal short-term, mid-term, and long-term rates are set forth for the month of April 2023. See Rev. Rul. 2023-6, page 627.
Section 382.—Limitation on Net Operating Loss Carryforwards and Certain Built-In Losses Following Ownership Change
The adjusted applicable federal long-term rate is set forth for the month of April 2023. See Rev. Rul. 2023-6, page 627.
Section 467.—Certain Payments for the Use of Property or Services
The applicable federal short-term, mid-term, and long-term rates are set forth for the month of April 2023. See Rev. Rul. 2023-6, page 627.
Section 468.—Special Rules for Mining and Solid Waste Reclamation and Closing Costs
The applicable federal short-term rates are set forth for the month of April 2023. See Rev. Rul. 2023-6, page 627.
Section 482.—Allocation of Income and Deductions Among Taxpayers
The applicable federal short-term, mid-term, and long-term rates are set forth for the month of April 2023. See Rev. Rul. 2023-6, page 627.
Section 483.—Interest on Certain Deferred Payments
The applicable federal short-term, mid-term, and long-term rates are set forth for the month of April 2023. See Rev. Rul. 2023-6, page 627.
Section 1288.—Treatment of Original Issue Discount on Tax-Exempt Obligations
The adjusted applicable federal short-term, mid-term, and long-term rates are set forth for the month of April 2023. See Rev. Rul. 2023-6, page 627.
Section 7520.—Valuation Tables
The applicable federal mid-term rates are set forth for the month of April 2023. See Rev. Rul. 2023-6, page 627.
Section 7872.—Treatment of Loans With Below-Market Interest Rates
The applicable federal short-term, mid-term, and long-term rates are set forth for the month of April 2023. See Rev. Rul. 2023-6, page 627.
Source: official text