Rev. Rul. 2023-10

This revenue ruling provides various prescribed rates for federal income

tax purposes for June 2023 (the current month). Table 1 contains the shortterm, 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. 2023-10 TABLE 1 Applicable Federal Rates (AFR) for June 2023

Period for Compounding Annual Semiannual Quarterly Monthly Short-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% Mid-term AFR 3.56% 3.53% 3.51% 3.50% 110% AFR 3.92% 3.88% 3.86% 3.85% 120% AFR 4.28% 4.24% 4.22% 4.20% 130% AFR 4.64% 4.59% 4.56% 4.55% 150% AFR 5.37% 5.30% 5.27% 5.24% 175% AFR 6.28% 6.18% 6.13% 6.10% Long-term AFR 3.79% 3.75% 3.73% 3.72% 110% AFR 4.17% 4.13% 4.11% 4.09% 120% AFR 4.55% 4.50% 4.47% 4.46% 130% AFR 4.94% 4.88% 4.85% 4.83%

REV. RUL. 2023-10 TABLE 2

Adjusted AFR for June 2023

Period for Compounding Annual Semiannual Quarterly Monthly Short-term adjusted AFR 3.36% 3.33% 3.32% 3.31% Mid-term adjusted AFR 2.70% 2.68% 2.67% 2.67% Long-term adjusted AFR 2.87% 2.85% 2.84% 2.83%

June 5, 2023 884 Bulletin No. 2023–23

REV. RUL. 2023-10 TABLE 3 Rates Under Section 382 for June 2023 Adjusted federal long-term rate for the current month 2.87% Long-term tax-exempt rate for ownership changes during the current month (the highest of the adjusted federal 3.04% long-term rates for the current month and the prior two months.)

REV. RUL. 2023-10 TABLE 4 Appropriate Percentages Under Section 42(b)(1) for June 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 7.85% Appropriate percentage for the 30% present value low-income housing credit 3.36%

REV. RUL. 2023-10 TABLE 5 Rate Under Section 7520 for June 2023 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

4.20%

Section 42.—Low-Income Housing Credit

The applicable federal short-term, mid-term, and long-term rates are set forth for the month of June 2023. See Rev. Rul. 2023-10, page 884.

Section 280G.—Golden Parachute Payments

The applicable federal short-term, mid-term, and long-term rates are set forth for the month of June 2023. See Rev. Rul. 2023-10, page 884.

Section 382.—Limitation on Net Operating Loss Carryforwards and Certain Built-In Losses Following Ownership Change

The applicable federal short-term, mid-term, and long-term rates are set forth for the month of June 2023. See Rev. Rul. 2023-10, page 884.

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 June 2023. See Rev. Rul. 2023-10, page 884.

Section 468.—Special Rules for Mining and Solid Waste Reclamation and Closing Costs

The applicable federal short-term, mid-term, and long-term rates are set forth for the month of June 2023. See Rev. Rul. 2023-10, page 884.

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 June 2023. See Rev. Rul. 2023-10, page 884.

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 June 2023. See Rev. Rul. 2023-10, page 884.

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 June 2023. See Rev. Rul. 2023-10, page 884.

Section 7520.—Valuation Tables

The applicable federal mid-term rates are set forth for the month of June 2023. See Rev. Rul. 2023-10, page 884.

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 June 2023. See Rev. Rul. 2023-10, page 884.

Bulletin No. 2023–23 885 June 5, 2023

exceeding $10,000 for the calendar quarter beginning July 1, 2023, is 4.5 percent. The underpayment rate for large corporate underpayments for the calendar quarter beginning July 1, 2023, is 9 percent. These rates apply to amounts bearing interest during that calendar quarter.

Sections 6654(a)(1) and 6655(a) (1) provide that the underpayment rate established under section 6621 applies in determining the addition to tax under sections 6654 and 6655 for failure to pay estimated tax for any taxable year. Thus, the 7 percent rate also applies to estimated tax underpayments for the third calendar quarter beginning July 1, 2023. In addition, pursuant to section 6603(d)(4), the rate of interest on section 6603 deposits is 4 percent for the third calendar quarter in 2023. Interest factors for daily compound interest for annual rates of 4.5 percent, 6 percent, 7 percent and 9 percent are published in Tables 14, 17, 19 and 23 of Rev. Proc. 95-17, 1995-1 C.B. 568, 571, 573, and 577.

Annual interest rates to be compounded daily pursuant to section 6622 that apply for prior periods are set forth in the tables accompanying this revenue ruling.

DRAFTING INFORMATION

The principal author of this revenue ruling is Casey R. Conrad of the Office of the Associate Chief Counsel (Procedure and Administration). For further information regarding this revenue ruling, contact Mr. Conrad at (202) 317-6844 (not a tollfree number).

Section 6621.— Determination of Rate of Interest

26 CFR 301.6621-1: Interest rate.