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Rev. Rul. 2025-24, 2025-50 I.R.B. 764

Section 1274.—Determination of Issue Price in the Case of Certain Debt Instruments Issued for Property

activein force · 2025-12-08 – presentact-effective-date

This revenue ruling provides various prescribed rates for federal income tax purposes for December 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.

REV. RUL. 2025-24 TABLE 1 Applicable Federal Rates (AFR) for December 2025 Period for Compounding

Annual

Semiannual

Quarterly

Monthly

Short-term

AFR

3.66%

3.63%

3.61%

3.60%

110% AFR

4.03%

3.99%

3.97%

3.96%

120% AFR

4.41%

4.36%

4.34%

4.32%

130% AFR

4.78%

4.72%

4.69%

4.67%

Mid-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%

150% AFR

5.71%

5.63%

5.59%

5.57%

175% AFR

6.67%

6.56%

6.51%

6.47%

Long-term

AFR

4.55%

4.50%

4.47%

4.46%

110% AFR

5.01%

4.95%

4.92%

4.90%

120% AFR

5.47%

5.40%

5.36%

5.34%

130% AFR

5.94%

5.85%

5.81%

5.78%

REV. RUL. 2025-24 TABLE 2 Adjusted AFR for December 2025 Period for Compounding

Annual

Semiannual

Quarterly

Monthly

Short-term adjusted AFR

2.78%

2.76%

2.75%

2.74%

Mid-term adjusted AFR

2.87%

2.85%

2.84%

2.83%

Long-term adjusted AFR

3.45%

3.42%

3.41%

3.40%

REV. RUL. 2025-24 TABLE 3 Rates Under Section 382 for December 2025

Adjusted federal long-term rate for the current month

3.45%

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.)

3.58%

REV. RUL. 2025-24 TABLE 4 Appropriate Percentages Under Section 42(b)(1) for December 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

7.97%

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

3.41%

REV. RUL. 2025-24 TABLE 5 Rate Under Section 7520 for December 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%

Section 42.—Low-Income Housing Credit

The applicable federal short-term, mid-term, and long-term rates are set forth for the month of December 2025. See Rev. Rul. 2025-24, page 764.

Section 280G.—Golden Parachute Payments

The applicable federal short-term, mid-term, and long-term rates are set forth for the month of December 2025. See Rev. Rul. 2025-24 page 764.

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 December 2025. See Rev. Rul. 2025-24, page 764.

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 December 2025. See Rev. Rul. 2025-24, page 764.

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 December 2025. See Rev. Rul. 2025-24, page 764.

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 December 2025. See Rev. Rul. 2025-24, page 764.

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 December 2025. See Rev. Rul. 2025-24, page 764.

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 December 2025. See Rev. Rul. 2025-24, page 764.

Section 7520.—Valuation Tables

The applicable federal mid-term rates are set forth for the month of December 2025. See Rev. Rul. 2025-24, page 764.

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 December 2025. See Rev. Rul. 2025-24, page 764.

History

Revenue Ruling published in Internal Revenue Bulletin 2025-50, December 8, 2025, at page 764. It states no effective date of its own; this row opens at the bulletin's publication date. Filed under I.R.C. § 1274 (Section 1274.—Determination of Issue Price in the Case of Certain Debt Instruments Issued for Property).

Provenance

Source
irs.gov
Retrieved
2026-09-20
Edition
irs-irb-2026-09-20
Content hash
0e7ddb48da7eaa9f433e3a6a6c4e4740cf8f2f3a3615e77991d975c09e9c25d1
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