Section 1274.—Determi- nation of Issue Price in the Case of Certain Debt Instru- ments…

(Also Sections 42, 280G, 382, 412, 467, 468, 482, 483, 642, 807, 846, 1288, 7520, 7872.)

Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 642, 1274, 1288, and other sections of the Code, tables set forth the rates for April 2005.

REV. RUL. 2005–23 TABLE 1

Applicable Federal Rates (AFR) for April 2005

Period for Compounding

Annual Semiannual Quarterly Monthly

Short-term

AFR 3.35% 3.32% 3.31% 3.30% 110% AFR 3.68% 3.65% 3.63% 3.62% 120% AFR 4.02% 3.98% 3.96% 3.95% 130% AFR 4.37% 4.32% 4.30% 4.28%

2005–15 I.R.B. 864 April 11, 2005

REV. RUL. 2005–23 TABLE 1

Applicable Federal Rates (AFR) for April 2005 - Continued

Period for Compounding

Annual Semiannual Quarterly Monthly

Mid-term

AFR 4.09% 4.05% 4.03% 4.02% 110% AFR 4.51% 4.46% 4.44% 4.42% 120% AFR 4.92% 4.86% 4.83% 4.81% 130% AFR 5.34% 5.27% 5.24% 5.21% 150% AFR 6.17% 6.08% 6.03% 6.00% 175% AFR 7.22% 7.09% 7.03% 6.99%

Long-term

AFR 4.68% 4.63% 4.60% 4.59% 110% AFR 5.15% 5.09% 5.06% 5.04% 120% AFR 5.64% 5.56% 5.52% 5.50% 130% AFR 6.11% 6.02% 5.98% 5.95%

REV. RUL. 2005–23 TABLE 2

Adjusted AFR for April 2005

Period for Compounding

Annual Semiannual Quarterly Monthly

Short-term adjusted AFR 2.40% 2.39% 2.38% 2.38%

Mid-term adjusted AFR 3.03% 3.01% 3.00% 2.99%

Long-term adjusted AFR 4.19% 4.15% 4.13% 4.11%

REV. RUL. 2005–23 TABLE 3

Rates Under Section 382 for April 2005

Adjusted federal long-term rate for the current month 4.19%

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.) 4.20%

REV. RUL. 2005–23 TABLE 4

Appropriate Percentages Under Section 42(b)(2) for April 2005 Appropriate percentage for the 70% present value low-income housing credit 8.02%

Appropriate percentage for the 30% present value low-income housing credit 3.44%

April 11, 2005 865 2005–15 I.R.B.

REV. RUL. 2005–23 TABLE 5

Rate Under Section 7520 for April 2005

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 5.00%

2003–2 C.B. 1248) (the second temporary regulations) under section 1502 amending §1.1502–28T. A notice of proposed rulemaking (REG–153319–03, 2003–2 C.B. 1256) cross-referencing the second temporary regulations was published in the Federal Register for the same day (68 FR 69062). The second temporary regulations clarify that certain attributes that arise (or are treated as arising) in a separate return year are subject to reduction when no SRLY limitation applies to the use of such attributes.

On March 15, 2004, the IRS and Treasury Department published in the Fed- eral Register (69 FR 12069) temporary regulations (T.D. 9117, 2004–15 I.R.B. 721) (the third temporary regulations) under section 1502 amending §§1.1502–13 and 1.1502–28T. A notice of proposed rulemaking (REG–167265–03, 2004–15 I.R.B. 730) (the 2004 proposed regulations) cross-referencing the third temporary regulations was published in the Federal Register for the same day (69 FR 12091). The third temporary regulations address certain technical issues relating to the application of excluded COD income to reduce attributes under sections 108 and 1017 and §1.1502–28T. The 2004 proposed regulations, in addition to cross-referencing the third temporary regulations, proposed amendments to §§1.1502–28T and 1.1502–11 to provide a methodology for computing consolidated taxable income and for effecting attribute reduction when there is a disposition of the stock of a member in a year during which any member realizes excluded COD income.

No public hearing was requested or held for any of the regulations described above. Written and electronic comments responding to the notices of proposed rulemaking were received. After consideration of all the comments, the proposed regulations are adopted as revised by this Treasury decision, and the affected provisions in the