Bulletin No. 2023–19

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Bulletin No. 2023–19

May 8, 2023

These synopses are intended only as aids to the reader in

identifying the subject matter covered. They may not be

relied upon as authoritative interpretations.

ADMINISTRATIVE

Rev. Proc. 2023-22, page 838.

This Revenue Procedure provides issuers of qualified mortgage bonds, as defined in section 143(a) of the Internal

Revenue Code, and issuers of mortgage credit certificates,

as defined in section 25(c), with (1) nationwide average purchase prices for residences located in the United States, and

(2) average area purchase price safe harbors for residences

located in statistical areas in each state, the District of

Columbia, Puerto Rico, the Northern Mariana Islands, American Samoa, the Virgin Islands, and Guam.

EXEMPT ORGANIZATIONS

Announcement 2023-14, page 853.

Revocation of IRC 501(c)(3) Organizations for failure to meet

the code section requirements. Contributions made to the

organizations by individual donors are no longer deductible

under IRC 170(b)(1)(A).

INCOME TAX

Notice 2023-34, page 837.

The Notice updates the background section of Notice

2014-21 to reflect that certain foreign jurisdictions

have enacted laws that characterize Bitcoin as legal

tender. The Notice states that the change to the background section does not affect the answers to the FAQs

in section 4 of Notice 2014-21.

Finding Lists begin on page ii.

Rev. Proc. 2023-21, page 837.

Revenue Procedure 2023-21 provides domestic asset/

liability percentages and domestic investment yields

needed by foreign life insurance companies and foreign

property and liability insurance companies to compute

their minimum effectively connected net investment

income under section 842(b) of the Internal Revenue

Code for taxable years beginning after December 31,

2021.

Rev. Rul. 2023-9, page 835.

Federal rates; adjusted federal rates; adjusted federal longterm rate, and the long-term tax exempt rate. For purposes

of sections 382, 1274, 1288, 7872 and other sections of

the Code, tables set forth the rates for May 2023.

The IRS Mission

Provide America’s taxpayers top-quality service by helping

them understand and meet their tax responsibilities and

enforce the law with integrity and fairness to all.

Introduction

The Internal Revenue Bulletin is the authoritative instrument

of the Commissioner of Internal Revenue for announcing official rulings and procedures of the Internal Revenue Service

and for publishing Treasury Decisions, Executive Orders, Tax

Conventions, legislation, court decisions, and other items of

general interest. It is published weekly.

It is the policy of the Service to publish in the Bulletin all

substantive rulings necessary to promote a uniform application of the tax laws, including all rulings that supersede,

revoke, modify, or amend any of those previously published

in the Bulletin. All published rulings apply retroactively unless

otherwise indicated. Procedures relating solely to matters

of internal management are not published; however, statements of internal practices and procedures that affect the

rights and duties of taxpayers are published.

Revenue rulings represent the conclusions of the Service

on the application of the law to the pivotal facts stated in

the revenue ruling. In those based on positions taken in rulings to taxpayers or technical advice to Service field offices,

identifying details and information of a confidential nature are

deleted to prevent unwarranted invasions of privacy and to

comply with statutory requirements.

Rulings and procedures reported in the Bulletin do not have the

force and effect of Treasury Department Regulations, but they

may be used as precedents. Unpublished rulings will not be

relied on, used, or cited as precedents by Service personnel in

the disposition of other cases. In applying published rulings and

procedures, the effect of subsequent legislation, regulations,

court decisions, rulings, and procedures must be considered,

and Service personnel and others concerned are cautioned

against reaching the same conclusions in other cases unless

the facts and circumstances are substantially the same.

The Bulletin is divided into four parts as follows:

Part I.—1986 Code.

This part includes rulings and decisions based on provisions

of the Internal Revenue Code of 1986.

Part II.—Treaties and Tax Legislation.

This part is divided into two subparts as follows: Subpart A,

Tax Conventions and Other Related Items, and Subpart B,

Legislation and Related Committee Reports.

Part III.—Administrative, Procedural, and Miscellaneous.

To the extent practicable, pertinent cross references to these

subjects are contained in the other Parts and Subparts. Also

included in this part are Bank Secrecy Act Administrative

Rulings. Bank Secrecy Act Administrative Rulings are issued

by the Department of the Treasury’s Office of the Assistant

Secretary (Enforcement).

Part IV.—Items of General Interest.

This part includes notices of proposed rulemakings, disbarment and suspension lists, and announcements.

The last Bulletin for each month includes a cumulative index

for the matters published during the preceding months. These

monthly indexes are cumulated on a semiannual basis, and are

published in the last Bulletin of each semiannual period.

The contents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate.

May 8, 2023

Bulletin No. 2023–19

Part I

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. 2023-9

This revenue ruling provides various prescribed rates for federal income

Annual

AFR

110% AFR

120% AFR

130% AFR

4.30%

4.73%

5.17%

5.61%

AFR

110% AFR

120% AFR

130% AFR

150% AFR

175% AFR

3.57%

3.93%

4.30%

4.65%

5.38%

6.30%

AFR

110% AFR

120% AFR

130% AFR

3.72%

4.10%

4.48%

4.86%

Short-term adjusted AFR

Mid-term adjusted AFR

Long-term adjusted AFR

Bulletin No. 2023–19

tax purposes for May 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 appropri-

ate 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. 2023-9 TABLE 1

Applicable Federal Rates (AFR) for May 2023

Period for Compounding

Semiannual

Quarterly

Short-term

4.25%

4.23%

4.68%

4.65%

5.10%

5.07%

5.53%

5.49%

Mid-term

3.54%

3.52%

3.89%

3.87%

4.25%

4.23%

4.60%

4.57%

5.31%

5.28%

6.20%

6.15%

Long-term

3.69%

3.67%

4.06%

4.04%

4.43%

4.41%

4.80%

4.77%

Annual

3.26%

2.71%

2.82%

REV. RUL. 2023-9 TABLE 2

Adjusted AFR for May 2023

Period for Compounding

Semiannual

3.23%

2.69%

2.80%

835

Quarterly

3.22%

2.68%

2.79%

Monthly

4.21%

4.64%

5.05%

5.47%

3.51%

3.86%

4.21%

4.56%

5.25%

6.12%

3.66%

4.03%

4.39%

4.75%

Monthly

3.21%

2.68%

2.78%

May 8, 2023

REV. RUL. 2023-9 TABLE 3

Rates Under Section 382 for May 2023

Adjusted federal long-term rate for the current month

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.)

2.82%

3.04%

REV. RUL. 2023-9 TABLE 4

Appropriate Percentages Under Section 42(b)(1) for May 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

7.84%

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

3.36%

REV. RUL. 2023-9 TABLE 5

Rate Under Section 7520 for May 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

Section 42.—Low-Income

Housing Credit

The applicable federal short-term, mid-term,

and long-term rates are set forth for the month of

May 2023. See Rev. Rul. 2023-9, page 835.

Section 280G.—Golden

Parachute Payments

The applicable federal short-term, mid-term,

and long-term rates are set forth for the month of

May 2023. See Rev. Rul. 2023-9, page 835.

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 May 2023. See Rev.

Rul. 2023-9, page 835.

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

May 2023. See Rev. Rul. 2023-9, page 835.

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 May 2023. See Rev. Rul.

2023-9, page 835.

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

May 2023. See Rev. Rul. 2023-9, page 835.

4.40%

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

May 2023. See Rev. Rul. 2023-9, page 835.

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 May 2023. See Rev. Rul. 2023-9, page

835.

Section 7520.—Valuation

Tables

The applicable federal mid-term rates are set

forth for the month of May 2023. See Rev. Rul.

2023-9, page 835.

Section 7872.—Treatment

of Loans With BelowMarket Interest Rates

The applicable federal short-term, mid-term,

and long-term rates are set forth for the month of

May 2023. See Rev. Rul. 2023-9, page 835.

May 8, 2023

836

Bulletin No. 2023–19

Part III

Notice 2023-34

Modification of Notice 2014-21

SECTION 1. PURPOSE

Notice 2014-21, 2014-16 I.R.B. 938,

provides that convertible virtual currency is treated as property for federal

tax purposes and that general tax principles applicable to property transactions

apply to transactions using convertible

virtual currency. This Notice modifies

Notice 2014-21 by revising a sentence in

the Background section of that Notice to

remove the statement that virtual currency

does not have legal tender status in any

jurisdiction and to make other changes.

This Notice also explains that the revision to the Background section of Notice

2014-21 does not affect the answers to

the frequently asked questions (FAQs) set

forth in section 4 of Notice 2014-21.

SECTION 2. BACKGROUND

Notice 2014-21 describes how existing

general tax principles apply to transactions using convertible virtual currency.1

The Notice provides the guidance in the

form of FAQs.

Notice 2014-21 provides that convertible virtual currency is treated as property

for federal tax purposes and that general tax principles applicable to property

transactions apply to transactions using

convertible virtual currency. The Background section of Notice 2014-21 defines

virtual currency as a digital representation

of value that functions as a medium of

exchange, a unit of account, and/or a store

of value. The Background section also

states that virtual currency does not have

legal tender status in any jurisdiction. Rev.

Rul. 2019-24, 2019-44 I.R.B. 1004, subsequently clarified that virtual currency

does not include a representation of the

United States dollar or a foreign currency.

The Background section of Notice

2014-21 describes convertible virtual

currency as virtual currency that has an

equivalent value in real currency, or that

acts as a substitute for real currency. The

Background section of the Notice also

identifies Bitcoin as an example of a convertible virtual currency and explains that

Bitcoin can be digitally traded between

users and can be purchased for, or

exchanged into, U.S. dollars, Euros, and

other real or virtual currencies.

This change to the Background section of Notice 2014-21 does not affect

the answers to the FAQs set forth in

section 4 of Notice 2014-21, including

Q&A-2, which concludes that convertible virtual currency is not treated as

currency that could generate foreign

currency gain or loss for U.S. federal

tax purposes.

SECTION 3. MODIFICATION OF

NOTICE 2014-21

This Notice modifies Notice 2014-21

by revising its “Background” section.

The Department of the Treasury and

the Internal Revenue Service are aware

that certain foreign jurisdictions have

enacted laws that characterize Bitcoin

as legal tender. Thus, the sentence in

the Background section of Notice 201421 stating that virtual currency does not

have legal tender status in any jurisdiction is no longer accurate as to Bitcoin.

In addition, the Background section of

Notice 2014-21 may be misinterpreted

as overstating the similarity between

convertible virtual currency and “real”

currency because the use of convertible virtual currency, including Bitcoin,

to perform “real” currency functions is

limited.2 Accordingly, Notice 2014-21 is

modified by revising the third sentence

in the first paragraph of the Background

section to read as follows:

SECTION 5. DRAFTING

INFORMATION

In certain contexts, virtual currency

may serve one or more of the functions

of “real” currency – i.e., the coin and

paper money of the United States or of

any other country that is designated as

legal tender, circulates, and is customarily used and accepted as a medium

of exchange in the country of issuance – but the use of virtual currency

to perform “real” currency functions is

limited.

SECTION 4. EFFECT ON OTHER

DOCUMENTS

The principal author of this Notice is

Raphael J. Cohen of the Office of Associate Chief Counsel (International). For

further information regarding this Notice,

contact Raphael J. Cohen at (202) 3176938 (not a toll-free number).

26 CFR 601.105: Examination of returns and claims

for refund, credit or abatement; determination of tax

liability

(Also: 842(b))

Rev. Proc. 2023-21

SECTION 1. PURPOSE

This revenue procedure provides the

domestic asset/liability percentages and

domestic investment yields needed by foreign life insurance companies and foreign

property and liability insurance companies to compute their minimum effectively

connected net investment income under

section 842(b) of the Internal Revenue

Code for taxable years beginning after

December 31, 2021. Instructions are provided for computing foreign insurance

While the Background section of Notice 2014-21 describes both virtual currency and convertible virtual currency, Section 3 of Notice 2014-21 explains that the term “virtual currency” as

used in section 4 of the Notice refers only to convertible virtual currency.

See U.S. Department of the Treasury, Crypto-Assets: Implications for Consumers, Investors and Businesses at 1 and 20 (September 2022), available at https://home.treasury.gov/system/

files/136/CryptoAsset_EO5.pdf. See also OECD, Taxing Virtual Currencies: An Overview of Tax Treatments and Emerging Tax Policy Issues, at 20 (Oct. 12, 2020), available at https://www.

oecd.org/tax/tax-policy/taxing-virtual-currencies-an-overview-of-tax-treatments-and-emerging-tax-policy-issues.pdf.

Bulletin No. 2023–19

837

May 8, 2023

companies’ liabilities for the estimated tax

and installment payments of estimated tax

for taxable years beginning after December 31, 2021. For more specific guidance

regarding the computation of the amount

of net investment income to be included

by a foreign insurance company on its

U.S. income tax return, see Notice 89-96,

1989-2 C.B. 417. For the domestic asset/

liability percentage and domestic investment yield, as well as instructions for

computing foreign insurance companies’

liabilities for estimated tax and installment payments of estimated tax for

taxable years beginning after December

31, 2020, see Rev. Proc. 2022-36, 202240 I.R.B. 274.

SECTION 2. PERCENTAGES AND

YIELDS

.01 DOMESTIC ASSET/LIABILITY

PERCENTAGES FOR 2022. The Secretary determines the domestic asset/

liability percentage separately for life

insurance companies and property and

liability insurance companies. For the first

taxable year beginning after December 31,

2021, the relevant domestic asset/liability

percentages are:

1 27.7 percent for foreign life insurance

companies, and

199.7 percent for foreign property and

liability insurance companies.

.02 DOMESTIC INVESTMENT

YIELDS FOR 2022. The Secretary is

required to prescribe separate domestic

investment yields for foreign life insurance companies and for foreign property

and liability insurance companies. For

the first taxable year beginning after

December 31, 2021, the relevant domestic

investment yields are:

3 .0 percent for foreign life insurance

companies, and

2.4 percent for foreign property and

liability insurance companies.

.03 SOURCE OF DATA FOR 2022.

The section 842(b) percentages to be used

for the 2022 taxable year are based on tax

return data from the 2020 taxable year.

May 8, 2023

SECTION 3. ESTIMATED TAXES

To compute estimated tax and the

installment payments of estimated tax

due for taxable years beginning after

December 31, 2021, a foreign insurance

company must compute its estimated

tax payments by adding to its income

other than net investment income the

greater of (i) its net investment income

as determined under section 842(b)(5)

that is actually effectively connected

with the conduct of a trade or business

within the United States for the relevant

period, or (ii) the minimum effectively

connected net investment income under

section 842(b) that would result from

using the most recently available domestic asset/liability percentage and domestic

investment yield. Thus, for installment

payments due after the publication of this

revenue procedure, the domestic asset/

liability percentages and the domestic

investment yields provided in this revenue procedure must be used to compute

the minimum effectively connected net

investment income. However, if the due

date of an installment is less than 20 days

after the date this revenue procedure is

published in the Internal Revenue Bulletin, the asset/liability percentages and

domestic investment yields provided in

Rev. Proc. 2022-36 may be used to compute the minimum effectively connected

net investment income for such installment. For further guidance in computing

estimated tax, see Notice 89-96.

SECTION 4. EFFECTIVE DATE

This revenue procedure is effective for

taxable years beginning after December

31, 2021.

SECTION 5. DRAFTING

INFORMATION

The principal author of this revenue procedure is Sheila Ramaswamy of

the Office of Associate Chief Counsel

(International). For further information

regarding this revenue procedure contact

Sheila Ramaswamy at (202) 317-6938

(not a toll free number).

838

26 CFR 601.601: Rules and Regulations

(Also Part 1, §§ 25, 143, 6a.103A-1(b)(4), 6a.103A2(f)(5)).

Rev. Proc. 2023-22

SECTION 1. PURPOSE

This revenue procedure provides

issuers of qualified mortgage bonds, as

defined in § 143(a) of the Internal Revenue Code (Code), and issuers of mortgage

credit certificates, as defined in § 25(c),

with (1) the nationwide average purchase

price for residences located in the United

States, and (2) average area purchase price

safe harbors for residences located in statistical areas in each state, the District of

Columbia, Puerto Rico, the Northern Mariana Islands, American Samoa, the Virgin

Islands, and Guam. Section 7 of this revenue procedure requests comments on the

available data and method used for calculating the average area purchase price safe

harbors.

SECTION 2. BACKGROUND

.01 Section 103(a) provides that, except

as provided in § 103(b), gross income

does not include interest on any State or

local bond. Section 103(b)(1) provides

that § 103(a) shall not apply to any private activity bond that is not a “qualified

bond” within the meaning of § 141. Section 141(e) provides, in part, that the term

“qualified bond” means any private activity bond if such bond (1) is a qualified

mortgage bond under § 143, (2) meets

the volume cap requirements under § 146,

and (3) meets the applicable requirements

under § 147.

.02 Section 143(a)(1) provides that the

term “qualified mortgage bond” means a

bond that is issued as part of a qualified

mortgage issue. Section 143(a)(2)(A)

provides that the term “qualified mortgage issue” means an issue of one or more

bonds by a State or political subdivision

thereof, but only if: (i) all proceeds of the

issue (exclusive of issuance costs and a

reasonably required reserve) are to be used

to finance owner-occupied residences; (ii)

the issue meets the requirements of subsections (c), (d), (e), (f), (g), (h), (i), and (m)

Bulletin No. 2023–19

(7) of § 143; (iii) the issue does not meet

the private business tests of paragraphs (1)

and (2) of § 141(b); and (iv) with respect

to amounts received more than 10 years

after the date of issuance, repayments of

$250,000 or more of principal on mortgage

financing provided by the issue are used

by the close of the first semiannual period

beginning after the date the prepayment (or

complete repayment) is received to redeem

bonds that are part of the issue.

Average Area Purchase Price

.03 Section 143(e)(1) provides that an

issue of bonds meets the purchase price

requirements of § 143(e) if the acquisition cost of each residence financed by

the issue does not exceed 90 percent of

the average area purchase price applicable

to such residence. Section 143(e)(5) provides that, in the case of a targeted area

residence (as defined in § 143(j)), § 143(e)

(1) shall be applied by substituting 110

percent for 90 percent.

.04 Section 143(e)(2) provides that the

term “average area purchase price” means,

with respect to any residence, the average

purchase price of single-family residences

(in the statistical area in which the residence is located) that were purchased

during the most recent 12-month period

for which sufficient statistical information

is available. Under §§ 143(e)(3) and (4),

respectively, separate determinations of

average area purchase price are to be made

for new and existing residences, and for

two-, three-, and four-family residences.

.05 Section 143(e)(2) also provides that

the determination of the average area purchase price shall be made as of the date

on which the commitment to provide the

financing is made or, if earlier, the date of

the purchase of the residence.

.06 Section 143(k)(2)(A) provides that

the term “statistical area” means (i) a metropolitan statistical area (MSA), and (ii)

any county (or the portion thereof) that

is not within an MSA. Section 143(k)

(2)(C) further provides that if sufficient

recent statistical information with respect

to a county (or portion thereof) is unavailable, the Secretary may substitute another

area for which there is sufficient recent

statistical information for such county (or

portion thereof). In the case of any portion

of a State which is not within a county, §

Bulletin No. 2023–19

143(k)(2)(D) provides that the Secretary

may designate an area that is the equivalent of a county. Section 6a.103A-1(b)(4)

(i) of the Income Tax Regulations (issued

under § 103A of the Internal Revenue

Code of 1954, the predecessor of § 143 of

the Code) provides that the term “State”

includes a possession of the United States

and the District of Columbia.

.07 Section 6a.103A-2(f)(5)(i) provides

that an issuer may rely upon the average

area purchase price safe harbors published

by the Department of the Treasury (Treasury Department) for the statistical area

in which a residence is located. Section

6a.103A-2(f)(5)(i) further provides that

an issuer may use an average area purchase price limitation different from the

published safe harbor if the issuer has

more accurate and comprehensive data for

the statistical area.

Qualified Mortgage Credit Certificate

Program

.08 Section 25(c) permits a State or

political subdivision thereof to establish

a qualified mortgage credit certificate program. In general, a qualified mortgage

credit certificate program is a program

under which the issuing authority elects

not to issue an amount of private activity

bonds that it may otherwise issue during

the calendar year under § 146, and in its

place, issues mortgage credit certificates

to taxpayers in connection with the

acquisition of their principal residences.

Section 25(a)(1) provides, in general, that

the holder of a mortgage credit certificate

may claim a federal income tax credit

equal to the product of the credit rate

specified in the certificate and the interest

paid or accrued during the tax year on the

remaining principal of the indebtedness

incurred to acquire the residence. Section

25(c)(2)(A)(iii)(III) generally provides

that residences acquired in connection

with the issuance of mortgage credit certificates must meet the purchase price

requirements of § 143(e).

Income Limitations for Qualified

Mortgage Bonds and Mortgage Credit

Certificates

.09 Section 143(f) imposes limitations

on the income of mortgagors for whom

839

financing may be provided by qualified

mortgage bonds. In addition, § 25(c)

(2)(A)(iii)(IV) provides that holders of

mortgage credit certificates must meet

the income requirement of § 143(f). Generally, under §§ 143(f)(1) and 25(c)(2)(A)

(iii)(IV), the income requirement is met

only if all owner-financing under a qualified mortgage bond and all mortgage

credit certificates issued under a qualified

mortgage credit certificate program are

provided to mortgagors whose family

income is 115 percent or less of the applicable median family income. Section

143(f)(5), however, generally provides

for an upward adjustment to the percentage limitation in high housing cost areas.

High housing cost areas are defined in §

143(f)(5)(C) as any statistical area for

which the housing cost/income ratio is

greater than 1.2.

.10 Under § 143(f)(5)(D), the housing cost/income ratio with respect to any

statistical area is determined by dividing

(a) the applicable housing price ratio for

such area by (b) the ratio that the area

median gross income for such area bears

to the median gross income for the United

States. The applicable housing price ratio

is the new housing price ratio (new housing average area purchase price divided

by the new housing average purchase

price for the United States) or the existing housing price ratio (existing housing

average area purchase price divided by the

existing housing average purchase price

for the United States), whichever results

in the housing cost/income ratio being

closer to 1.

Average Area and Nationwide Purchase

Price Limitations

.11 Average area purchase price safe

harbors for each state, the District of

Columbia, Puerto Rico, the Northern Mariana Islands, American Samoa, the Virgin

Islands, and Guam were last published in

Rev. Proc. 2022-21, 2022-16 I.R.B. 1015.

.12 The nationwide average purchase

price was last published in section 4.02 of

Rev. Proc. 2022-21. Guidance with respect

to the United States and area median gross

income figures that are used in computing

the housing cost/income ratio described in

§ 143(f)(5) was published in Rev. Proc.

2021-19, 2021-15 I.R.B. 1008.

May 8, 2023

.13 This revenue procedure uses Federal Housing Administration (FHA) loan

limits for a given statistical area to calculate the average area purchase price

safe harbor for that area. FHA sets limits

on the dollar value of loans it will insure

based on median home prices and conforming loan limits established by the

Federal Home Loan Mortgage Corporation. In particular, FHA sets an area’s

loan limit at 95 percent of the median

home sales price for the area, subject to

certain floors and caps measured against

conforming loan limits.

.14 To calculate the average area

purchase price safe harbors in this revenue procedure, the FHA loan limits are

adjusted to take into account the differences between average and median

purchase prices. Because FHA loan limits

do not differentiate between new and existing residences, this revenue procedure

contains a single average area purchase

price safe harbor for both new and existing residences in a statistical area.

.15 The average area purchase price

safe harbors listed in section 4.01 of this

revenue procedure are based on FHA loan

limits released December 1, 2022. FHA

loan limits are available for statistical areas

in each state, the District of Columbia,

Puerto Rico, the Northern Mariana Islands,

American Samoa, the Virgin Islands, and

Guam. See section 3.03 of this revenue

procedure with respect to FHA loan limits

revised after December 1, 2022.

.16 OMB Bulletin No. 03-04, dated

and effective June 6, 2003, revised the

definitions of the nation’s metropolitan

areas and recognized 49 new metropolitan statistical areas. The OMB bulletin

no longer includes primary metropolitan

statistical areas.

SECTION 3. APPLICATION

Average Area Purchase Price Safe

Harbors

.01 Average area purchase price safe

harbors for statistical areas in each state,

the District of Columbia, Puerto Rico,

the Northern Mariana Islands, American

Samoa, the Virgin Islands, and Guam are

set forth in section 4.01 of this revenue

procedure. Average area purchase price

safe harbors are provided for single-fam-

May 8, 2023

ily and two to four-family residences. For

each type of residence, section 4.01 of this

revenue procedure contains a single safe

harbor that may be used for both new and

existing residences. Issuers of qualified

mortgage bonds and issuers of mortgage

credit certificates may rely on these safe

harbors to satisfy the requirements of §§

143(e) and (f). Section 4.01 of this revenue procedure provides safe harbors for

MSAs and for certain counties and county

equivalents. If no purchase price safe harbor is available for a statistical area, the

safe harbor for “ALL OTHER AREAS”

may be used for that statistical area.

.02 If a residence is in an MSA, the safe

harbor applicable to it is the limitation of

that MSA. If an MSA falls in more than

one state, the MSA is listed in section 4.01

of this revenue procedure under each state.

.03 If the FHA revises the FHA loan

limit for any statistical area after December 1, 2022, an issuer of qualified mortgage

bonds or mortgage credit certificates may

use the revised FHA loan limit for that

statistical area to compute (as provided in

the next sentence) a revised average area

purchase price safe harbor for the statistical area provided that the issuer maintains

records evidencing the revised FHA loan

limit. The revised average area purchase

price safe harbor for that statistical area

is computed by dividing the revised FHA

loan limit by 0.883.

.04 If, pursuant to § 6a.103A-2(f)(5)

(i), an issuer uses more accurate and comprehensive data to determine the average

area purchase price for a statistical area,

the issuer must make separate average area

purchase price determinations for new and

existing residences. Moreover, when computing the average area purchase price for a

statistical area that is an MSA, as defined in

OMB Bulletin No. 03-04, the issuer must

make the computation for the entire applicable MSA. When computing the average

area purchase price for a statistical area

that is not an MSA, the issuer must make

the computation for the entire statistical

area and may not combine statistical areas.

Thus, for example, the issuer may not combine two or more counties.

.05 If an issuer receives a ruling permitting it to rely on an average area

purchase price limitation that is higher

than the applicable safe harbor in this revenue procedure, the issuer may rely on

840

that higher limitation for the purpose of

satisfying the requirements of §§ 143(e)

and (f) for bonds sold, and mortgage

credit certificates issued, not more than 30

months following the termination date of

the 12-month period used by the issuer to

compute the limitation.

Nationwide Average Purchase Price

.06 Section 4.02 of this revenue procedure sets forth a single nationwide

average purchase price for purposes of

computing the housing cost/income ratio

under § 143(f)(5).

.07 Issuers must use the nationwide

average purchase price set forth in section 4.02 of this revenue procedure when

computing the housing cost/income ratio

under § 143(f)(5) regardless of whether

they are relying on the average area purchase price safe harbors contained in this

revenue procedure or using more accurate and comprehensive data to determine

average area purchase prices for new and

existing residences for a statistical area

that are different from the published safe

harbors in this revenue procedure.

.08 If, pursuant to section 6.02 of this

revenue procedure, an issuer relies on the

average area purchase price safe harbors

contained in Rev. Proc. 2022-21, the issuer

must use the nationwide average purchase

price set forth in section 4.02 of Rev. Proc.

2022-21 in computing the housing cost/

income ratio under § 143(f)(5). Likewise,

if, pursuant to section 6.04 of this revenue

procedure, an issuer relies on the nationwide average purchase price published in

Rev. Proc. 2022-21, the issuer must use

the average area purchase price safe harbors set forth in section 4.01 of Rev. Proc.

2022-21 in computing the housing cost/

income ratio under § 143(f)(5).

SECTION 4. AVERAGE AREA

AND NATIONWIDE AVERAGE

PURCHASE PRICES

.01 Average area purchase prices for

single-family and two to four-family

residences in MSAs, and for certain counties and county equivalents are set forth

below. The safe harbor for “ALL OTHER

AREAS” (found at the end of the table

below) may be used for a statistical area

that is not listed below.

Bulletin No. 2023–19

2023 Average Area Purchase Prices for Mortgage Revenue Bonds

State

One-Unit

Limit

Two-Unit

Limit

Three-Unit

Limit

Four-Unit

Limit

ALEUTIANS WEST

$617,402

$790,356

$955,382

$1,187,347

HOONAH-ANGOON C

$593,957

$760,341

$919,081

$1,142,211

JUNEAU CITY AND

$604,377

$773,707

$935,221

$1,162,259

KETCHIKAN GATEW

$549,670

$703,653

$850,556

$1,057,093

KODIAK ISLAND B

$549,670

$703,653

$850,556

$1,057,093

SITKA CITY AND

$664,293

$850,386

$1,027,928

$1,277,505

SKAGWAY MUNICIP

$593,957

$760,341

$919,081

$1,142,211

COCONINO

$586,141

$750,374

$907,018

$1,127,204

MARICOPA

$600,469

$768,723

$929,161

$1,154,783

PINAL

$600,469

$768,723

$929,161

$1,154,783

ALAMEDA

$1,233,785

$1,579,778

$1,909,461

$2,373,108

County Name

ALPINE

$563,998

$722,001

$872,756

$1,084,616

CONTRA COSTA

$1,233,785

$1,579,778

$1,909,461

$2,373,108

EL DORADO

$864,884

$1,107,212

$1,338,384

$1,663,282

INYO

$575,721

$737,009

$890,878

$1,107,156

LOS ANGELES

$1,233,785

$1,579,778

$1,909,461

$2,373,108

MARIN

$1,233,785

$1,579,778

$1,909,461

$2,373,108

MENDOCINO

$618,705

$792,055

$957,421

$1,189,839

MONO

$785,429

$1,005,501

$1,215,436

$1,510,489

MONTEREY

$1,036,819

$1,327,341

$1,604,441

$1,993,900

NAPA

$1,152,745

$1,475,717

$1,783,795

$2,216,860

NEVADA

$729,420

$933,805

$1,128,733

$1,402,775

ORANGE

$1,233,785

$1,579,778

$1,909,461

$2,373,108

PLACER

$864,884

$1,107,212

$1,338,384

$1,663,282

RIVERSIDE

$729,420

$933,805

$1,128,733

$1,402,775

SACRAMENTO

$864,884

$1,107,212

$1,338,384

$1,663,282

SAN BENITO

$1,233,785

$1,579,778

$1,909,461

$2,373,108

SAN BERNARDINO

$729,420

$933,805

$1,128,733

$1,402,775

SAN DIEGO

$1,107,156

$1,417,386

$1,713,288

$2,129,194

SAN FRANCISCO

$1,233,785

$1,579,778

$1,909,461

$2,373,108

SAN JOAQUIN

$743,748

$952,154

$1,150,932

$1,430,298

SAN LUIS OBISPO

$1,032,911

$1,322,301

$1,598,382

$1,986,424

SAN MATEO

$1,233,785

$1,579,778

$1,909,461

$2,373,108

SANTA BARBARA

$911,775

$1,167,242

$1,410,930

$1,753,440

SANTA CLARA

$1,233,785

$1,579,778

$1,909,461

$2,373,108

SANTA CRUZ

$1,233,785

$1,579,778

$1,909,461

$2,373,108

SOLANO

$776,312

$993,835

$1,201,278

$1,492,933

SONOMA

$975,600

$1,248,962

$1,509,696

$1,876,162

Bulletin No. 2023–19

841

May 8, 2023

State

One-Unit

Limit

Two-Unit

Limit

Three-Unit

Limit

Four-Unit

Limit

STANISLAUS

$586,141

$750,374

$907,018

$1,127,204

SUTTER

$553,578

$708,693

$856,616

$1,064,569

VENTURA

$1,074,592

$1,375,705

$1,662,886

$2,066,559

YOLO

$864,884

$1,107,212

$1,338,384

$1,663,282

YUBA

$553,578

$708,693

$856,616

$1,064,569

ADAMS

$892,237

$1,142,211

$1,380,688

$1,715,893

ARAPAHOE

$892,237

$1,142,211

$1,380,688

$1,715,893

BOULDER

$970,389

$1,242,280

$1,501,654

$1,866,195

BROOMFIELD

$892,237

$1,142,211

$1,380,688

$1,715,893

CHAFFEE

$679,924

$870,434

$1,052,166

$1,307,576

CLEAR CREEK

$892,237

$1,142,211

$1,380,688

$1,715,893

DENVER

$892,237

$1,142,211

$1,380,688

$1,715,893

DOUGLAS

$892,237

$1,142,211

$1,380,688

$1,715,893

EAGLE

$1,217,871

$1,559,136

$1,884,600

$2,342,130

EL PASO

$586,141

$750,374

$907,018

$1,127,204

ELBERT

$892,237

$1,142,211

$1,380,688

$1,715,893

GARFIELD

$1,233,785

$1,579,778

$1,909,461

$2,373,108

GILPIN

$892,237

$1,142,211

$1,380,688

$1,715,893

GRAND

$758,076

$970,446

$1,173,075

$1,457,878

GUNNISON

$588,746

$753,715

$911,039

$1,132,187

JEFFERSON

$892,237

$1,142,211

$1,380,688

$1,715,893

LA PLATA

$676,016

$865,394

$1,046,106

$1,300,044

LARIMER

$695,554

$890,425

$1,076,348

$1,337,648

PARK

$892,237

$1,142,211

$1,380,688

$1,715,893

PITKIN

$1,233,785

$1,579,778

$1,909,461

$2,373,108

ROUTT

$957,364

$1,225,630

$1,481,493

$1,841,107

SAN JUAN

$573,116

$733,668

$886,857

$1,102,172

SAN MIGUEL

$1,184,005

$1,515,756

$1,832,215

$2,277,003

SUMMIT

$1,079,803

$1,382,331

$1,670,927

$2,076,583

TELLER

$586,141

$750,374

$907,018

$1,127,204

WELD

$629,125

$805,364

$973,504

$1,209,886

FAIRFIELD

$801,060

$1,025,492

$1,239,618

$1,540,504

DISTRICT OF COL

$1,233,785

$1,579,778

$1,909,461

$2,373,108

NEW CASTLE

$599,167

$767,024

$927,179

$1,152,235

BAKER

$596,562

$763,683

$923,158

$1,147,251

BROWARD

$631,730

$808,705

$977,582

$1,214,870

CLAY

$596,562

$763,683

$923,158

$1,147,251

County Name

May 8, 2023

842

Bulletin No. 2023–19

State

One-Unit

Limit

Two-Unit

Limit

Three-Unit

Limit

Four-Unit

Limit

COLLIER

$761,984

$975,486

$1,179,135

$1,465,353

DUVAL

$596,562

$763,683

$923,158

$1,147,251

County Name

MANATEE

$573,116

$733,668

$886,857

$1,102,172

MARTIN

$566,603

$725,343

$876,777

$1,089,657

MIAMI-DADE

$631,730

$808,705

$977,582

$1,214,870

MONROE

$989,928

$1,267,311

$1,531,839

$1,903,742

NASSAU

$596,562

$763,683

$923,158

$1,147,251

OKALOOSA

$683,832

$875,418

$1,058,169

$1,315,052

PALM BEACH

$631,730

$808,705

$977,582

$1,214,870

SARASOTA

$573,116

$733,668

$886,857

$1,102,172

ST. JOHNS

$596,562

$763,683

$923,158

$1,147,251

ST. LUCIE

$566,603

$725,343

$876,777

$1,089,657

WALTON

$683,832

$875,418

$1,058,169

$1,315,052

BARROW

$670,806

$858,768

$1,038,008

$1,290,021

BARTOW

$670,806

$858,768

$1,038,008

$1,290,021

BUTTS

$670,806

$858,768

$1,038,008

$1,290,021

CARROLL

$670,806

$858,768

$1,038,008

$1,290,021

CHEROKEE

$670,806

$858,768

$1,038,008

$1,290,021

CLARKE

$584,839

$748,675

$904,980

$1,124,712

CLAYTON

$670,806

$858,768

$1,038,008

$1,290,021

COBB

$670,806

$858,768

$1,038,008

$1,290,021

COWETA

$670,806

$858,768

$1,038,008

$1,290,021

DAWSON

$670,806

$858,768

$1,038,008

$1,290,021

DEKALB

$670,806

$858,768

$1,038,008

$1,290,021

DOUGLAS

$670,806

$858,768

$1,038,008

$1,290,021

FAYETTE

$670,806

$858,768

$1,038,008

$1,290,021

FORSYTH

$670,806

$858,768

$1,038,008

$1,290,021

FULTON

$670,806

$858,768

$1,038,008

$1,290,021

GREENE

$583,536

$747,033

$902,997

$1,122,220

GWINNETT

$670,806

$858,768

$1,038,008

$1,290,021

HARALSON

$670,806

$858,768

$1,038,008

$1,290,021

HEARD

$670,806

$858,768

$1,038,008

$1,290,021

HENRY

$670,806

$858,768

$1,038,008

$1,290,021

JASPER

$670,806

$858,768

$1,038,008

$1,290,021

LAMAR

$670,806

$858,768

$1,038,008

$1,290,021

MADISON

$584,839

$748,675

$904,980

$1,124,712

MERIWETHER

$670,806

$858,768

$1,038,008

$1,290,021

MORGAN

$670,806

$858,768

$1,038,008

$1,290,021

NEWTON

$670,806

$858,768

$1,038,008

$1,290,021

OCONEE

$584,839

$748,675

$904,980

$1,124,712

OGLETHORPE

$584,839

$748,675

$904,980

$1,124,712

Bulletin No. 2023–19

843

May 8, 2023

State

One-Unit

Limit

Two-Unit

Limit

Three-Unit

Limit

Four-Unit

Limit

PAULDING

$670,806

$858,768

$1,038,008

$1,290,021

PICKENS

$670,806

$858,768

$1,038,008

$1,290,021

PIKE

$670,806

$858,768

$1,038,008

$1,290,021

ROCKDALE

$670,806

$858,768

$1,038,008

$1,290,021

SPALDING

$670,806

$858,768

$1,038,008

$1,290,021

WALTON

$670,806

$858,768

$1,038,008

$1,290,021

HAWAII

$586,141

$750,374

$907,018

$1,127,204

HONOLULU

$872,699

$1,117,236

$1,350,447

$1,678,290

KALAWAO

$1,107,156

$1,417,386

$1,713,288

$2,129,194

KAUAI

$1,107,156

$1,417,386

$1,713,288

$2,129,194

MAUI

$1,107,156

$1,417,386

$1,713,288

$2,129,194

ADA

$664,293

$850,386

$1,027,928

$1,277,505

BLAINE

$838,833

$1,073,856

$1,298,062

$1,613,163

BOISE

$664,293

$850,386

$1,027,928

$1,277,505

BONNER

$592,654

$758,699

$917,099

$1,139,719

CAMAS

$838,833

$1,073,856

$1,298,062

$1,613,163

CANYON

$664,293

$850,386

$1,027,928

$1,277,505

FRANKLIN

$557,486

$713,677

$862,675

$1,072,101

GEM

$664,293

$850,386

$1,027,928

$1,277,505

KOOTENAI

$648,663

$830,395

$1,003,746

$1,247,433

OWYHEE

$664,293

$850,386

$1,027,928

$1,277,505

TETON

$1,233,785

$1,579,778

$1,909,461

$2,373,108

VALLEY

$649,966

$832,094

$1,005,784

$1,249,925

BARNSTABLE

$794,547

$1,017,168

$1,229,538

$1,527,988

BRISTOL

$748,958

$958,780

$1,158,974

$1,440,322

DUKES

$1,233,785

$1,579,778

$1,909,461

$2,373,108

ESSEX

$937,826

$1,200,599

$1,451,252

$1,803,560

MIDDLESEX

$937,826

$1,200,599

$1,451,252

$1,803,560

NANTUCKET

$1,233,785

$1,579,778

$1,909,461

$2,373,108

NORFOLK

$937,826

$1,200,599

$1,451,252

$1,803,560

PLYMOUTH

$937,826

$1,200,599

$1,451,252

$1,803,560

SUFFOLK

$937,826

$1,200,599

$1,451,252

$1,803,560

ANNE ARUNDEL

$716,395

$917,099

$1,108,572

$1,377,687

BALTIMORE

$716,395

$917,099

$1,108,572

$1,377,687

BALTIMORE CITY

$716,395

$917,099

$1,108,572

$1,377,687

CALVERT

$1,233,785

$1,579,778

$1,909,461

$2,373,108

CARROLL

$716,395

$917,099

$1,108,572

$1,377,687

CECIL

$599,167

$767,024

$927,179

$1,152,235

County Name

May 8, 2023

844

Bulletin No. 2023–19

State

One-Unit

Limit

Two-Unit

Limit

Three-Unit

Limit

Four-Unit

Limit

CHARLES

$1,233,785

$1,579,778

$1,909,461

$2,373,108

FREDERICK

$1,233,785

$1,579,778

$1,909,461

$2,373,108

HARFORD

$716,395

$917,099

$1,108,572

$1,377,687

HOWARD

$716,395

$917,099

$1,108,572

$1,377,687

MONTGOMERY

$1,233,785

$1,579,778

$1,909,461

$2,373,108

PRINCE GEORGE'S

$1,233,785

$1,579,778

$1,909,461

$2,373,108

QUEEN ANNE'S

$716,395

$917,099

$1,108,572

$1,377,687

CUMBERLAND

$573,116

$733,668

$886,857

$1,102,172

SAGADAHOC

$573,116

$733,668

$886,857

$1,102,172

YORK

$573,116

$733,668

$886,857

$1,102,172

ANOKA

$583,536

$747,033

$902,997

$1,122,220

CARVER

$583,536

$747,033

$902,997

$1,122,220

CHISAGO

$583,536

$747,033

$902,997

$1,122,220

DAKOTA

$583,536

$747,033

$902,997

$1,122,220

HENNEPIN

$583,536

$747,033

$902,997

$1,122,220

ISANTI

$583,536

$747,033

$902,997

$1,122,220

LE SUEUR

$583,536

$747,033

$902,997

$1,122,220

MILLE LACS

$583,536

$747,033

$902,997

$1,122,220

RAMSEY

$583,536

$747,033

$902,997

$1,122,220

SCOTT

$583,536

$747,033

$902,997

$1,122,220

SHERBURNE

$583,536

$747,033

$902,997

$1,122,220

WASHINGTON

$583,536

$747,033

$902,997

$1,122,220

WRIGHT

$583,536

$747,033

$902,997

$1,122,220

BROADWATER

$565,301

$723,700

$874,738

$1,087,108

FLATHEAD

$626,520

$802,079

$969,483

$1,204,846

GALLATIN

$797,152

$1,020,509

$1,233,558

$1,533,029

MISSOULA

$618,705

$792,055

$957,421

$1,189,839

PARK

$610,889

$782,031

$945,302

$1,174,774

RAVALLI

$571,813

$732,025

$884,819

$1,099,624

CAMDEN

$574,418

$735,367

$888,896

$1,104,664

County Name

CHATHAM

$682,529

$873,775

$1,056,187

$1,312,560

CURRITUCK

$574,418

$735,367

$888,896

$1,104,664

DARE

$683,832

$875,418

$1,058,169

$1,315,052

DURHAM

$682,529

$873,775

$1,056,187

$1,312,560

FRANKLIN

$569,208

$728,684

$880,798

$1,094,640

GATES

$574,418

$735,367

$888,896

$1,104,664

GRANVILLE

$682,529

$873,775

$1,056,187

$1,312,560

Bulletin No. 2023–19

845

May 8, 2023

State

One-Unit

Limit

Two-Unit

Limit

Three-Unit

Limit

Four-Unit

Limit

HYDE

$547,065

$700,311

$846,535

$1,052,053

JOHNSTON

$569,208

$728,684

$880,798

$1,094,640

ORANGE

$682,529

$873,775

$1,056,187

$1,312,560

PASQUOTANK

$911,775

$1,167,242

$1,410,930

$1,753,440

PERQUIMANS

$911,775

$1,167,242

$1,410,930

$1,753,440

PERSON

$682,529

$873,775

$1,056,187

$1,312,560

WAKE

$569,208

$728,684

$880,798

$1,094,640

DAWSON

$683,832

$875,418

$1,058,169

$1,315,052

GOSPER

$683,832

$875,418

$1,058,169

$1,315,052

HILLSBOROUGH

$540,553

$691,987

$836,455

$1,039,537

ROCKINGHAM

$937,826

$1,200,599

$1,451,252

$1,803,560

STRAFFORD

$937,826

$1,200,599

$1,451,252

$1,803,560

BERGEN

$1,233,785

$1,579,778

$1,909,461

$2,373,108

BURLINGTON

$599,167

$767,024

$927,179

$1,152,235

CAMDEN

$599,167

$767,024

$927,179

$1,152,235

CAPE MAY

$621,310

$795,397

$961,442

$1,194,822

ESSEX

$1,233,785

$1,579,778

$1,909,461

$2,373,108

GLOUCESTER

$599,167

$767,024

$927,179

$1,152,235

HUDSON

$1,233,785

$1,579,778

$1,909,461

$2,373,108

HUNTERDON

$1,233,785

$1,579,778

$1,909,461

$2,373,108

MIDDLESEX

$1,233,785

$1,579,778

$1,909,461

$2,373,108

MONMOUTH

$1,233,785

$1,579,778

$1,909,461

$2,373,108

MORRIS

$1,233,785

$1,579,778

$1,909,461

$2,373,108

OCEAN

$1,233,785

$1,579,778

$1,909,461

$2,373,108

PASSAIC

$1,233,785

$1,579,778

$1,909,461

$2,373,108

SALEM

$599,167

$767,024

$927,179

$1,152,235

SOMERSET

$1,233,785

$1,579,778

$1,909,461

$2,373,108

SUSSEX

$1,233,785

$1,579,778

$1,909,461

$2,373,108

UNION

$1,233,785

$1,579,778

$1,909,461

$2,373,108

LOS ALAMOS

$660,386

$845,403

$1,021,925

$1,269,973

SANTA FE

$570,511

$730,326

$882,836

$1,097,132

CARSON CITY

$573,116

$733,668

$886,857

$1,102,172

CLARK

$560,091

$717,018

$866,696

$1,077,084

DOUGLAS

$745,051

$953,796

$1,152,914

$1,432,790

STOREY

$703,370

$900,449

$1,088,411

$1,352,656

WASHOE

$703,370

$900,449

$1,088,411

$1,352,656

County Name

May 8, 2023

846

Bulletin No. 2023–19

State

One-Unit

Limit

Two-Unit

Limit

Three-Unit

Limit

Four-Unit

Limit

BRONX

$1,233,785

$1,579,778

$1,909,461

$2,373,108

KINGS

$1,233,785

$1,579,778

$1,909,461

$2,373,108

NASSAU

$1,233,785

$1,579,778

$1,909,461

$2,373,108

NEW YORK

$1,233,785

$1,579,778

$1,909,461

$2,373,108

PUTNAM

$1,233,785

$1,579,778

$1,909,461

$2,373,108

QUEENS

$1,233,785

$1,579,778

$1,909,461

$2,373,108

RICHMOND

$1,233,785

$1,579,778

$1,909,461

$2,373,108

ROCKLAND

$1,233,785

$1,579,778

$1,909,461

$2,373,108

SUFFOLK

$1,233,785

$1,579,778

$1,909,461

$2,373,108

WESTCHESTER

$1,233,785

$1,579,778

$1,909,461

$2,373,108

DELAWARE

$553,578

$708,693

$856,616

$1,064,569

FAIRFIELD

$553,578

$708,693

$856,616

$1,064,569

FRANKLIN

$553,578

$708,693

$856,616

$1,064,569

HOCKING

$553,578

$708,693

$856,616

$1,064,569

LICKING

$553,578

$708,693

$856,616

$1,064,569

MADISON

$553,578

$708,693

$856,616

$1,064,569

MORROW

$553,578

$708,693

$856,616

$1,064,569

PERRY

$553,578

$708,693

$856,616

$1,064,569

PICKAWAY

$553,578

$708,693

$856,616

$1,064,569

UNION

$553,578

$708,693

$856,616

$1,064,569

BENTON

$634,335

$812,046

$981,603

$1,219,910

CLACKAMAS

$761,984

$975,486

$1,179,135

$1,465,353

CLATSOP

$599,167

$767,024

$927,179

$1,152,235

COLUMBIA

$761,984

$975,486

$1,179,135

$1,465,353

DESCHUTES

$781,522

$1,000,461

$1,209,377

$1,502,957

HOOD RIVER

$760,681

$973,787

$1,177,096

$1,462,861

LANE

$545,763

$698,669

$844,553

$1,049,561

MARION

$547,065

$700,311

$846,535

$1,052,053

MULTNOMAH

$761,984

$975,486

$1,179,135

$1,465,353

POLK

$547,065

$700,311

$846,535

$1,052,053

WASHINGTON

$761,984

$975,486

$1,179,135

$1,465,353

YAMHILL

$761,984

$975,486

$1,179,135

$1,465,353

BUCKS

$599,167

$767,024

$927,179

$1,152,235

CHESTER

$599,167

$767,024

$927,179

$1,152,235

DELAWARE

$599,167

$767,024

$927,179

$1,152,235

MONTGOMERY

$599,167

$767,024

$927,179

$1,152,235

PHILADELPHIA

$599,167

$767,024

$927,179

$1,152,235

PIKE

$1,233,785

$1,579,778

$1,909,461

$2,373,108

County Name

Bulletin No. 2023–19

847

May 8, 2023

State

One-Unit

Limit

Two-Unit

Limit

Three-Unit

Limit

Four-Unit

Limit

BRISTOL

$748,958

$958,780

$1,158,974

$1,440,322

KENT

$748,958

$958,780

$1,158,974

$1,440,322

County Name

NEWPORT

$748,958

$958,780

$1,158,974

$1,440,322

PROVIDENCE

$748,958

$958,780

$1,158,974

$1,440,322

WASHINGTON

$748,958

$958,780

$1,158,974

$1,440,322

BEAUFORT

$549,670

$703,653

$850,556

$1,057,093

BERKELEY

$609,587

$780,389

$943,319

$1,172,283

CHARLESTON

$609,587

$780,389

$943,319

$1,172,283

DORCHESTER

$609,587

$780,389

$943,319

$1,172,283

JASPER

$549,670

$703,653

$850,556

$1,057,093

CANNON

$1,008,163

$1,290,644

$1,560,099

$1,938,797

CHEATHAM

$1,008,163

$1,290,644

$1,560,099

$1,938,797

DAVIDSON

$1,008,163

$1,290,644

$1,560,099

$1,938,797

DICKSON

$1,008,163

$1,290,644

$1,560,099

$1,938,797

MACON

$1,008,163

$1,290,644

$1,560,099

$1,938,797

MAURY

$1,008,163

$1,290,644

$1,560,099

$1,938,797

ROBERTSON

$1,008,163

$1,290,644

$1,560,099

$1,938,797

RUTHERFORD

$1,008,163

$1,290,644

$1,560,099

$1,938,797

SMITH

$1,008,163

$1,290,644

$1,560,099

$1,938,797

SUMNER

$1,008,163

$1,290,644

$1,560,099

$1,938,797

TROUSDALE

$1,008,163

$1,290,644

$1,560,099

$1,938,797

WILLIAMSON

$1,008,163

$1,290,644

$1,560,099

$1,938,797

WILSON

$1,008,163

$1,290,644

$1,560,099

$1,938,797

ATASCOSA

$593,957

$760,341

$919,081

$1,142,211

BANDERA

$593,957

$760,341

$919,081

$1,142,211

BASTROP

$647,361

$828,753

$1,001,764

$1,244,941

BEXAR

$593,957

$760,341

$919,081

$1,142,211

CALDWELL

$647,361

$828,753

$1,001,764

$1,244,941

COLLIN

$601,772

$770,365

$931,200

$1,157,275

COMAL

$593,957

$760,341

$919,081

$1,142,211

DALLAS

$601,772

$770,365

$931,200

$1,157,275

DENTON

$601,772

$770,365

$931,200

$1,157,275

ELLIS

$601,772

$770,365

$931,200

$1,157,275

GUADALUPE

$593,957

$760,341

$919,081

$1,142,211

HAYS

$647,361

$828,753

$1,001,764

$1,244,941

HUNT

$601,772

$770,365

$931,200

$1,157,275

JOHNSON

$601,772

$770,365

$931,200

$1,157,275

KAUFMAN

$601,772

$770,365

$931,200

$1,157,275

May 8, 2023

848

Bulletin No. 2023–19

State

One-Unit

Limit

Two-Unit

Limit

Three-Unit

Limit

Four-Unit

Limit

KENDALL

$593,957

$760,341

$919,081

$1,142,211

MEDINA

$593,957

$760,341

$919,081

$1,142,211

PARKER

$601,772

$770,365

$931,200

$1,157,275

ROCKWALL

$601,772

$770,365

$931,200

$1,157,275

TARRANT

$601,772

$770,365

$931,200

$1,157,275

TRAVIS

$647,361

$828,753

$1,001,764

$1,244,941

WILLIAMSON

$647,361

$828,753

$1,001,764

$1,244,941

WILSON

$593,957

$760,341

$919,081

$1,142,211

WISE

$601,772

$770,365

$931,200

$1,157,275

BOX ELDER

$842,741

$1,078,840

$1,304,122

$1,620,695

CACHE

$557,486

$713,677

$862,675

$1,072,101

DAVIS

$842,741

$1,078,840

$1,304,122

$1,620,695

GRAND

$616,100

$788,714

$953,400

$1,184,798

JUAB

$681,226

$872,076

$1,054,148

$1,310,068

MORGAN

$842,741

$1,078,840

$1,304,122

$1,620,695

RICH

$601,772

$770,365

$931,200

$1,157,275

SALT LAKE

$702,067

$898,750

$1,086,428

$1,350,164

SUMMIT

$1,233,785

$1,579,778

$1,909,461

$2,373,108

TOOELE

$702,067

$898,750

$1,086,428

$1,350,164

UTAH

$681,226

$872,076

$1,054,148

$1,310,068

WASATCH

$1,233,785

$1,579,778

$1,909,461

$2,373,108

WASHINGTON

$672,109

$860,410

$1,040,047

$1,292,512

WEBER

$842,741

$1,078,840

$1,304,122

$1,620,695

ALBEMARLE

$574,418

$735,367

$888,896

$1,104,664

ALEXANDRIA CITY

$1,233,785

$1,579,778

$1,909,461

$2,373,108

AMELIA

$618,705

$792,055

$957,421

$1,189,839

ARLINGTON

$1,233,785

$1,579,778

$1,909,461

$2,373,108

CHARLES CITY

$618,705

$792,055

$957,421

$1,189,839

CHARLOTTESVILLE

$574,418

$735,367

$888,896

$1,104,664

CHESAPEAKE CITY

$574,418

$735,367

$888,896

$1,104,664

CHESTERFIELD

$618,705

$792,055

$957,421

$1,189,839

CLARKE

$1,233,785

$1,579,778

$1,909,461

$2,373,108

COLONIAL HEIGHT

$618,705

$792,055

$957,421

$1,189,839

CULPEPER

$1,233,785

$1,579,778

$1,909,461

$2,373,108

DINWIDDIE

$618,705

$792,055

$957,421

$1,189,839

FAIRFAX

$1,233,785

$1,579,778

$1,909,461

$2,373,108

FAIRFAX CITY

$1,233,785

$1,579,778

$1,909,461

$2,373,108

FALLS CHURCH CI

$1,233,785

$1,579,778

$1,909,461

$2,373,108

FAUQUIER

$1,233,785

$1,579,778

$1,909,461

$2,373,108

County Name

Bulletin No. 2023–19

849

May 8, 2023

State

One-Unit

Limit

Two-Unit

Limit

Three-Unit

Limit

Four-Unit

Limit

FLUVANNA

$574,418

$735,367

$888,896

$1,104,664

FRANKLIN CITY

$574,418

$735,367

$888,896

$1,104,664

County Name

FREDERICKSBURG

$1,233,785

$1,579,778

$1,909,461

$2,373,108

GLOUCESTER

$574,418

$735,367

$888,896

$1,104,664

GOOCHLAND

$618,705

$792,055

$957,421

$1,189,839

GREENE

$574,418

$735,367

$888,896

$1,104,664

HAMPTON CITY

$574,418

$735,367

$888,896

$1,104,664

HANOVER

$618,705

$792,055

$957,421

$1,189,839

HENRICO

$618,705

$792,055

$957,421

$1,189,839

HOPEWELL CITY

$618,705

$792,055

$957,421

$1,189,839

ISLE OF WIGHT

$574,418

$735,367

$888,896

$1,104,664

JAMES CITY

$574,418

$735,367

$888,896

$1,104,664

KING AND QUEEN

$618,705

$792,055

$957,421

$1,189,839

KING WILLIAM

$618,705

$792,055

$957,421

$1,189,839

LOUDOUN

$1,233,785

$1,579,778

$1,909,461

$2,373,108

MADISON

$1,233,785

$1,579,778

$1,909,461

$2,373,108

MANASSAS CITY

$1,233,785

$1,579,778

$1,909,461

$2,373,108

MANASSAS PARK C

$1,233,785

$1,579,778

$1,909,461

$2,373,108

MATHEWS

$574,418

$735,367

$888,896

$1,104,664

NELSON

$574,418

$735,367

$888,896

$1,104,664

NEW KENT

$618,705

$792,055

$957,421

$1,189,839

NEWPORT NEWS CI

$574,418

$735,367

$888,896

$1,104,664

NORFOLK CITY

$574,418

$735,367

$888,896

$1,104,664

PETERSBURG CITY

$618,705

$792,055

$957,421

$1,189,839

POQUOSON CITY

$574,418

$735,367

$888,896

$1,104,664

PORTSMOUTH CITY

$574,418

$735,367

$888,896

$1,104,664

POWHATAN

$618,705

$792,055

$957,421

$1,189,839

PRINCE GEORGE

$618,705

$792,055

$957,421

$1,189,839

PRINCE WILLIAM

$1,233,785

$1,579,778

$1,909,461

$2,373,108

RAPPAHANNOCK

$1,233,785

$1,579,778

$1,909,461

$2,373,108

RICHMOND CITY

$618,705

$792,055

$957,421

$1,189,839

SOUTHAMPTON

$574,418

$735,367

$888,896

$1,104,664

SPOTSYLVANIA

$1,233,785

$1,579,778

$1,909,461

$2,373,108

STAFFORD

$1,233,785

$1,579,778

$1,909,461

$2,373,108

SUFFOLK CITY

$574,418

$735,367

$888,896

$1,104,664

SUSSEX

$618,705

$792,055

$957,421

$1,189,839

VIRGINIA BEACH

$574,418

$735,367

$888,896

$1,104,664

WARREN

$1,233,785

$1,579,778

$1,909,461

$2,373,108

WILLIAMSBURG CI

$574,418

$735,367

$888,896

$1,104,664

YORK

$574,418

$735,367

$888,896

$1,104,664

May 8, 2023

850

Bulletin No. 2023–19

State

One-Unit

Limit

Two-Unit

Limit

Three-Unit

Limit

Four-Unit

Limit

CHITTENDEN

$557,486

$713,677

$862,675

$1,072,101

FRANKLIN

$557,486

$713,677

$862,675

$1,072,101

GRAND ISLE

$557,486

$713,677

$862,675

$1,072,101

CHELAN

$573,116

$733,668

$886,857

$1,102,172

CLARK

$761,984

$975,486

$1,179,135

$1,465,353

DOUGLAS

$573,116

$733,668

$886,857

$1,102,172

ISLAND

$651,268

$833,736

$1,007,823

$1,252,474

KING

$1,107,156

$1,417,386

$1,713,288

$2,129,194

KITSAP

$638,243

$817,087

$987,662

$1,227,386

KITTITAS

$537,947

$688,645

$832,434

$1,034,497

PIERCE

$1,107,156

$1,417,386

$1,713,288

$2,129,194

SAN JUAN

$563,998

$722,001

$872,756

$1,084,616

SKAGIT

$617,402

$790,356

$955,382

$1,187,347

SKAMANIA

$761,984

$975,486

$1,179,135

$1,465,353

SNOHOMISH

$1,107,156

$1,417,386

$1,713,288

$2,129,194

THURSTON

$618,705

$792,055

$957,421

$1,189,839

WHATCOM

$683,832

$875,418

$1,058,169

$1,315,052

PIERCE

$583,536

$747,033

$902,997

$1,122,220

ST. CROIX

$583,536

$747,033

$902,997

$1,122,220

JEFFERSON

$1,233,785

$1,579,778

$1,909,461

$2,373,108

SHERIDAN

$554,880

$710,335

$858,655

$1,067,060

TETON

$1,233,785

$1,579,778

$1,909,461

$2,373,108

GUAM

$638,243

$817,087

$987,662

$1,227,386

NORTHERN ISLAND

$593,957

$760,341

$919,081

$1,142,211

SAIPAN

$599,167

$767,024

$927,179

$1,152,235

TINIAN

$603,074

$772,064

$933,239

$1,159,767

CULEBRA

$603,074

$772,064

$933,239

$1,159,767

ST. JOHN ISLAND

$1,090,223

$1,395,696

$1,687,068

$2,096,630

ST. THOMAS ISLA

$659,083

$843,760

$1,019,886

$1,267,481

$534,640

$684,568

$827,422

$1,028,324

County Name

All other areas - 2823 counties (floor):

Bulletin No. 2023–19

851

May 8, 2023

.02 The nationwide average purchase

price (for use in the housing cost/income

ratio for new and existing residences) is

$503,300.

SECTION 5. EFFECT ON OTHER

DOCUMENTS

Rev. Proc. 2022-21 is obsolete except

as provided in section 6 of this revenue

procedure.

SECTION 6. EFFECTIVE DATES

.01 Issuers may rely on this revenue

procedure to determine average area purchase price safe harbors for commitments

to provide financing or issue mortgage

credit certificates that are made, or (if

the purchase precedes the commitment)

for residences that are purchased, in the

period that begins on April 20, 2023,

and ends on the date as of which the safe

harbors contained in section 4.01 of this

revenue procedure are rendered obsolete

by a new revenue procedure.

.02 Notwithstanding section 5 of this

revenue procedure, issuers may continue to

rely on the average area purchase price safe

harbors contained in Rev. Proc. 2022-21,

with respect to bonds sold, or for mortgage credit certificates issued with respect

to bond authority exchanged, before May

20, 2023, if the commitments to provide

financing or issue mortgage credit certificates are made on or before June 19, 2023.

.03 Except as provided in section 6.04,

issuers must use the nationwide average

purchase price limitation contained in

this revenue procedure for commitments

to provide financing or issue mortgage

credit certificates that are made, or (if the

purchase precedes the commitment) for

residences that are purchased, in the period

that begins on April 20, 2023, and ends on

the date when the nationwide average purchase price limitation is rendered obsolete

by a new revenue procedure.

.04 Notwithstanding sections 5 and

6.03 of this revenue procedure, issuers

may continue to rely on the nationwide

average purchase price set forth in Rev.

May 8, 2023

Proc. 2022-21 with respect to bonds sold,

or for mortgage credit certificates issued

with respect to bond authority exchanged,

before May 20, 2023, if the commitments

to provide financing or issue mortgage

credit certificates are made on or before

June 19, 2023.

SECTION 7. REQUEST FOR

COMMENTS

.01 Comments Regarding Guidance in

this Revenue Procedure.

The Treasury Department and the IRS

request comments on whether there are

other sources of average purchase price

data, including data that differentiate

between new and existing residences, that

could provide a different method for calculating average area purchase price safe

harbors.

.02 Procedures for Submitting Comments.

(1) Deadline.

Written comments

should be submitted by June 19, 2023.

(2) Form and manner. The subject line

for the comments should include a reference to Revenue Procedure 2023-22. All

commenters are strongly encouraged to

submit comments electronically. However, comments may be submitted in one

of two ways:

(a) Electronically via the Federal

eRulemaking Portal at www.regulations.

gov (type IRS-2023-0018 in the search

field on the regulations.gov homepage to

find this notice and submit comments); or

(b) By mail to: Internal Revenue

Service, CC:PA:LPD:PR (Revenue Procedure 2023-22), Room 5203, P.O. Box

7604, Ben Franklin Station, Washington,

D.C., 20044.

(3) Publication of comments. The

Treasury Department and the IRS will

publish for public availability any comment submitted electronically or on paper

to its public docket on regulations.gov.

SECTION 8. PAPERWORK

REDUCTION ACT

The collection of information contained in this revenue procedure has been

852

reviewed and approved by the Office

of Management and Budget in accordance with the Paperwork Reduction Act

(44 U.S.C. 3507) under control number

1545-1877.

An agency may not conduct or sponsor,

and a person is not required to respond

to, a collection of information unless the

collection of information displays a valid

OMB control number.

This revenue procedure contains a

collection of information requirement

in section 3.03. The purpose of the collection of information is to verify the

applicable FHA loan limit that issuers of

qualified mortgage bonds and qualified

mortgage certificates have used to calculate the average area purchase price for

a given metropolitan statistical area for

purposes of §§ 143(e) and 25(c). The collection of information is required to obtain

the benefit of using revisions to FHA loan

limits to determine average area purchase

prices. The likely respondents are state

and local governments.

The estimated total annual report

ing and/or recordkeeping burden is:

15 hours.

The estimated annual burden per

respondent

and/or

recordkeeper:

15 minutes.

The estimated number of respondents

and/or recordkeepers: 60.

Books or records relating to a collection of information must be retained as

long as their contents may become material in the administration of any internal

revenue law. Generally, tax returns and

tax return information are confidential, as

required by 26 U.S.C. 6103.

SECTION 9. DRAFTING

INFORMATION

The principal authors of this revenue procedure are Zoran Stojanovic and

David White of the Office of Associate

Chief Counsel (Financial Institutions

& Products). For further information

regarding this revenue procedure contact

Mr. White at (202) 317-4562 (not a tollfree number).

Bulletin No. 2023–19

Part IV

Deletions From Cumulative

List of Organizations,

Contributions to Which are

Deductible Under Section

170 of the Code

Announcement 2023-14

The Internal Revenue Service has

revoked its determination that the

organizations listed below qualify as organizations described in sections 501(c)(3)

and 170(c)(2) of the Internal Revenue

Code of 1986.

Generally, the IRS will not disallow

deductions for contributions made to

NAME OF ORGANIZATION

Sarah and Mary’s Helping Hands

Little People Christian Day Care

Foundation for Better Health

New Life Ministries, Inc.

Project Transition USA, Inc.

Bulletin No. 2023–19

a listed organization on or before the

date of announcement in the Internal

Revenue Bulletin that an organization

no longer qualifies. However, the IRS

is not precluded from disallowing a

deduction for any contributions made

after an organization ceases to qualify

under section 170(c)(2) if the organization has not timely filed a suit for

declaratory judgment under section

7428 and if the contributor (1) had

knowledge of the revocation of the

ruling or determination letter, (2) was

aware that such revocation was imminent, or (3) was in part responsible for

or was aware of the activities or omissions of the organization that brought

about this revocation.

Effective Date of

Revocation

01/01/ 2020

01/01/2018

07/01/2020

01/01/2018

853

If on the other hand a suit for declaratory judgment has been timely filed,

contributions from individuals and organizations described in section 170(c)(2)

that are otherwise allowable will continue

to be deductible. Protection under section

7428(c) would begin on May 8, 2023 and

would end on the date the court first determines the organization is not described

in section 170(c)(2) as more particularly

set for in section 7428(c)(1). For individual contributors, the maximum deduction

protected is $1,000, with a husband and

wife treated as one contributor. This benefit is not extended to any individual, in

whole or in part, for the acts or omissions

of the organization that were the basis for

revocation.

LOCATION

Orland Park, IL

Maywood, IL

Costa Mesa, CA

San Marcos, CA

St. Petersburg, FL

May 8, 2023

Definition of Terms

Revenue rulings and revenue procedures

(hereinafter referred to as “rulings”) that

have an effect on previous rulings use the

following defined terms to describe the

effect:

Amplified describes a situation where

no change is being made in a prior published position, but the prior position is

being extended to apply to a variation of

the fact situation set forth therein. Thus, if

an earlier ruling held that a principle applied to A, and the new ruling holds that

the same principle also applies to B, the

earlier ruling is amplified. (Compare with

modified, below).

Clarified is used in those instances

where the language in a prior ruling is being made clear because the language has

caused, or may cause, some confusion. It

is not used where a position in a prior ruling is being changed.

Distinguished describes a situation

where a ruling mentions a previously published ruling and points out an essential

difference between them.

Modified is used where the substance

of a previously published position is being

changed. Thus, if a prior ruling held that a

principle applied to A but not to B, and the

new ruling holds that it applies to both A

and B, the prior ruling is modified because

it corrects a published position. (Compare

with amplified and clarified, above).

Obsoleted describes a previously published ruling that is not considered determinative with respect to future transactions.

This term is most commonly used in a ruling

that lists previously published rulings that

are obsoleted because of changes in laws or

regulations. A ruling may also be obsoleted

because the substance has been included in

regulations subsequently adopted.

Revoked describes situations where the

position in the previously published ruling

is not correct and the correct position is

being stated in a new ruling.

Superseded describes a situation where

the new ruling does nothing more than

restate the substance and situation of a

previously published ruling (or rulings).

Thus, the term is used to republish under

the 1986 Code and regulations the same

position published under the 1939 Code

and regulations. The term is also used

when it is desired to republish in a single

ruling a series of situations, names, etc.,

that were previously published over a

period of time in separate rulings. If the

new ruling does more than restate the substance of a prior ruling, a combination of

terms is used. For example, modified and

superseded describes a situation where the

substance of a previously published ruling

is being changed in part and is continued

without change in part and it is desired to

restate the valid portion of the previously published ruling in a new ruling that is

self contained. In this case, the previously

published ruling is first modified and then,

as modified, is superseded.

Supplemented is used in situations in

which a list, such as a list of the names of

countries, is published in a ruling and that

list is expanded by adding further names

in subsequent rulings. After the original

ruling has been supplemented several

times, a new ruling may be published that

includes the list in the original ruling and

the additions, and supersedes all prior rulings in the series.

Suspended is used in rare situations to

show that the previous published rulings

will not be applied pending some future

action such as the issuance of new or

amended regulations, the outcome of cases in litigation, or the outcome of a Service study.

Abbreviations

The following abbreviations in current

use and formerly used will appear in

material published in the Bulletin.

A—Individual.

Acq.—Acquiescence.

B—Individual.

BE—Beneficiary.

BK—Bank.

B.T.A.—Board of Tax Appeals.

C—Individual.

C.B.—Cumulative Bulletin.

CFR—Code of Federal Regulations.

CI—City.

COOP—Cooperative.

Ct.D.—Court Decision.

CY—County.

D—Decedent.

DC—Dummy Corporation.

DE—Donee.

Del. Order—Delegation Order.

DISC—Domestic International Sales Corporation.

DR—Donor.

E—Estate.

EE—Employee.

E.O.—Executive Order.

ER—Employer.

Bulletin No. 2023–19

ERISA—Employee Retirement Income Security Act.

EX—Executor.

F—Fiduciary.

FC—Foreign Country.

FICA—Federal Insurance Contributions Act.

FISC—Foreign International Sales Company.

FPH—Foreign Personal Holding Company.

F.R.—Federal Register.

FUTA—Federal Unemployment Tax Act.

FX—Foreign corporation.

G.C.M.—Chief Counsel’s Memorandum.

GE—Grantee.

GP—General Partner.

GR—Grantor.

IC—Insurance Company.

I.R.B.—Internal Revenue Bulletin.

LE—Lessee.

LP—Limited Partner.

LR—Lessor.

M—Minor.

Nonacq.—Nonacquiescence.

O—Organization.

P—Parent Corporation.

PHC—Personal Holding Company.

PO—Possession of the U.S.

PR—Partner.

PRS—Partnership.

PTE—Prohibited Transaction Exemption.

Pub. L.—Public Law.

REIT—Real Estate Investment Trust.

Rev. Proc.—Revenue Procedure.

Rev. Rul.—Revenue Ruling.

S—Subsidiary.

S.P.R.—Statement of Procedural Rules.

Stat.—Statutes at Large.

T—Target Corporation.

T.C.—Tax Court.

T.D.—Treasury Decision.

TFE—Transferee.

TFR—Transferor.

T.I.R.—Technical Information Release.

TP—Taxpayer.

TR—Trust.

TT—Trustee.

U.S.C.—United States Code.

X—Corporation.

Y—Corporation.

Z—Corporation.

May 8, 2023

Numerical Finding List1

Bulletin 2023–19

Announcements:

2023-2, 2023-2 I.R.B. 344

2023-1, 2023-3 I.R.B. 422

2023-3, 2023-5 I.R.B. 447

2023-4, 2023-7 I.R.B. 470

2023-5, 2023-9 I.R.B. 499

2023-6, 2023-9 I.R.B. 501

2023-8, 2023-14 I.R.B. 632

2023-9, 2023-15 I.R.B. 639

2023-10, 2023-16 I.R.B. 663

2023-7, 2023-17 I.R.B. 797

2023-11, 2023-17 I.R.B. 798

2023-12, 2023-17 I.R.B. 799

2023-13, 2023-18 I.R.B. 833

2023-14, 2023-19 I.R.B. 853

AOD:

2023-1, 2023-10 I.R.B. 502

2023-2, 2023-11 I.R.B. 529

Notices:

2023-4, 2023-2 I.R.B. 321

2023-5, 2023-2 I.R.B. 324

2023-6, 2023-2 I.R.B. 328

2023-8, 2023-2 I.R.B. 341

2023-1, 2023-3 I.R.B. 373

2023-2, 2023-3 I.R.B. 374

2023-3, 2023-3 I.R.B. 388

2023-7, 2023-3 I.R.B. 390

2023-9, 2023-3 I.R.B. 402

2023-10, 2023-3 I.R.B. 403

2023-11, 2023-3 I.R.B. 404

2023-12, 2023-6 I.R.B. 450

2023-13, 2023-6 I.R.B. 454

2023-16, 2023-8 I.R.B. 479

2023-17, 2023-10 I.R.B. 505

2023-18, 2023-10 I.R.B. 508

2023-20, 2023-10 I.R.B. 523

2023-19, 2023-11 I.R.B. 560

2023-21, 2023-11 I.R.B. 563

2023-22, 2023-12 I.R.B. 569

2023-23, 2023-13 I.R.B. 571

2023-24, 2023-13 I.R.B. 571

2023-26, 2023-13 I.R.B. 577

2023-25, 2023-14 I.R.B. 629

2023-27, 2023-15 I.R.B. 634

2023-28, 2023-15 I.R.B. 635

2023-31, 2023-16 I.R.B. 661

2023-30, 2023-17 I.R.B. 766

2023-33, 2023-18 I.R.B. 803

2023-34, 2023-19 I.R.B. 837

Proposed Regulations:

REG-100442-22, 2023-3 I.R.B. 423

REG-146537-06, 2023-3 I.R.B. 436

REG-114666-22, 2023-4 I.R.B. 437

REG 122286-18, 2023-11 I.R.B. 565

REG-120653-22, 2023-15 I.R.B. 640

REG-105954-22, 2023-16 I.R.B. 713

REG-120080-22, 2023-16 I.R.B. 746

REG 109309-22, 2023-17 I.R.B. 770

REG 121709-19, 2023-17 I.R.B. 789

Revenue Procedures:

2023-1, 2023-1 I.R.B. 1

2023-2, 2023-1 I.R.B. 120

2023-3, 2023-1 I.R.B. 144

2023-4, 2023-1 I.R.B. 162

2023-5, 2023-1 I.R.B. 265

2023-7, 2023-1 I.R.B. 305

2023-8, 2023-3 I.R.B. 407

2023-10, 2023-3 I.R.B. 411

2023-11, 2023-3 I.R.B. 417

2023-14, 2023-6 I.R.B. 466

2023-9, 2023-7 I.R.B. 471

2023-13, 2023-13 I.R.B. 581

2023-17, 2023-13 I.R.B. 604

2023-18, 2023-13 I.R.B. 605

2023-19, 2023-13 I.R.B. 626

2023-20, 2023-15 I.R.B. 636

2023-12, 2023-17 I.R.B. 768

2023-15, 2023-18 I.R.B. 806

2023-21, 2023-19 I.R.B. 837

2023-22, 2023-19 I.R.B. 838

Revenue Rulings:

2023-1, 2023-2 I.R.B. 309

2023-3, 2023-6 I.R.B. 448

2023-4, 2023-9 I.R.B. 480

2023-5, 2023-10 I.R.B. 503

2023-6, 2023-14 I.R.B. 627

2023-7, 2023-15 I.R.B. 633

2023-2, 2023-16 I.R.B. 658

2023-8, 2023-18 I.R.B. 801

2023-9, 2023-19 I.R.B. 835

Treasury Decisions:

9970, 2023-2 I.R.B. 311

9771, 2023-3 I.R.B. 346

9772, 2023-11 I.R.B. 530

9773, 2023-11 I.R.B. 557

A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2022–27 through 2022–52 is in Internal Revenue Bulletin

2022–52, dated December 27, 2022.

May 8, 2023

Bulletin No. 2023–19

Finding List of Current Actions on

Previously Published Items1

Bulletin 2023–19

A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2022–27 through 2022–52 is in Internal Revenue Bulletin

2022–52, dated December 27, 2022.

Bulletin No. 2023–19

iii

May 8, 2023

Internal Revenue Service

Washington, DC 20224

Official Business

Penalty for Private Use, $300

INTERNAL REVENUE BULLETIN

The Introduction at the beginning of this issue describes the purpose and content of this publication. The weekly Internal Revenue

Bulletins are available at www.irs.gov/irb/.

We Welcome Comments About the Internal Revenue Bulletin

If you have comments concerning the format or production of the Internal Revenue Bulletin or suggestions for improving it,

we would be pleased to hear from you. You can email us your suggestions or comments through the IRS Internet Home Page

www.irs.gov) or write to the Internal Revenue Service, Publishing Division, IRB Publishing Program Desk, 1111 Constitution Ave.

NW, IR-6230 Washington, DC 20224.

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.