Interest on Underpayments and Overpayments of Federal Taxes

HTML Version Copyright 1995-2025 Daniel B. Evans. All rights reserved.

(Current through June 2025)

Interest on underpayments of federal tax must accrue interest, compounded daily, at rates published quarterly by the Internal Revenue Service in accordance with section 6621 of the Internal Revenue Code. (See Rev. Proc. 95-17, 1995-1 C.B. 556, for rules on how to calculate compounded interest.)

The rates for the most recent twelve calendar quarters are as follows:

— Rates for Underpayments and Overpayments of Tax —

Calendar
Quarter
Underpayments & Noncorporate OverpaymentsCorporate
Overpayments
Large Corp.
Overpayments
Large Corp.
Underpayments
Jul-Sep 20225%4%2.5%7%
Oct-Dec 20226%5%3.5%8%
Jan-Mar 20237%6%4.5%9%
Apr-Jun 20237%6%4.5%9%
Jul-Sep 20237%6%4.5%9%
Oct-Dec 20238%7%5.5%10%
Jan-Mar 20248%7%5.5%10%
Apr-Jun 20248%7%5.5%10%
Jul-Sep 20248%7%5.5%10%
Oct-Dec 20248%7%5.5%10%
Jan-Mar 20257%6%4.5%9%
Apr-Jun 20257%6%4.5%9%

As can be seen from the above table, the interest rate that applies to overpayments of tax by individuals (and other noncorporate taxpayers) is the same rate that applies to underpayments of tax.

For corporations, the interest rate on overpayments of $10,000 or less is 1 point less than the rate for underpayments, and the interest rate on the portion of the overpayment in excess of $10,000 (i.e., “large” overpayments) is 2.5 points less than the rate on underpayments. Corporations also pay interest that is 2 points higher for “large corporate underpayments” (i.e., underpayments of more than $100,000).

The underpayment interest rates that have applied since 1987 are shown below.

— Rates for Underpayments —

YearFirst
Quarter
Second
Quarter
Third
Quarter
Fourth
Quarter
19879%9%9%10%
198811%10%10%11%
198911%12%12%11%
199011%11%11%11%
199111%10%10%10%
19929%8%8%7%
19937%7%7%7%
19947%7%8%9%
19959%10%9%9%
19969%8%9%9%
19979%9%9%9%
19989%8%8%8%
19997%8%8%8%
20008%9%9%9%
20019%8%7%7%
20026%6%6%6%
20035%5%5%4%
20044%5%4%5%
20055%6%6%7%
20067%7%8%8%
20078%8%8%8%
20087%6%5%6%
20095%4%4%4%
20104%4%4%4%
20113%4%4%3%
20123%3%3%3%
20133%3%3%3%
20143%3%3%3%
20153%3%3%3%
20163%4%4%4%
20174%4%4%4%
20184%5%5%5%
20196%6%5%5%
20205%5%3%3%
20213%3%3%3%
20223%4%5%6%
20237%7%7%8%
20248%8%8%8%
20257%7%

Section 7520 Rates

HTML Version Copyright 1995-2025 Daniel B. Evans. All rights reserved.


(Current through May 2025)

The § 7520 rate is used to discount the value of annuities, life estates, and remainders to present value, and is revised monthly. It is equal to 120% of the applicable federal mid-term rate under I.R.C. § 1274(d), but rounded to the nearest two-tenths of a percent.

Normally, the § 7520 rate for the month in which the gift or death occurs is used to calculated the gift or estate tax value of the annuity, life estate, or remainder. However, the income, gift, or estate tax value of a charitable life estate or remainder can be determined using the rate for the month in which the gift or death occurs or a rate for either of the two preceding months.

The § 7520 rate for a calendar month is usually announced by the Internal Revenue Service in the form of a Revenue Ruling that is released around the 18th of the preceding month. The following is a chart of the rates that have been announced by the IRS:

Jan.Feb.Mar.Apr.MayJun.Jul.Aug.Sep.Oct.Nov.Dec.
1989NANA11.2%*11.6%*11.6%11.2%10.6%10.0%9.6%10.2%10.0%9.8%
19909.6%9.8%10.2%10.6%10.6%11.0%10.6%10.4%10.2%10.6%10.6%10.2%
19919.8%9.6%9.4%9.6%9.6%9.6%9.6%9.8%9.6%9.0%8.6%8.4%
19928.2%7.6%8.0%8.4%8.6%8.4%8.2%7.8%7.2%7.0%6.8%7.4%
19937.6%7.6%7.0%6.6%6.6%6.4%6.6%6.4%6.4%6.0%6.0%6.2%
19946.4%6.4%6.4%7.0%7.8%8.4%8.2%8.4%8.4%8.6%9.0%9.4%
19959.6%9.6%9.4%8.8%8.6%8.2%7.6%7.2%7.6%7.6%7.4%7.2%
19966.8%6.8%6.6%7.0%7.6%8.0%8.2%8.2%8.0%8.0%8.0%7.6%
19977.4%7.6%7.8%7.8%8.2%8.2%8.0%7.6%7.6%7.6%7.4%7.2%
19987.2%6.8%6.8%6.8%6.8%7.0%6.8%6.8%6.6%6.2%5.4%5.4%
19995.6%5.6%5.8%6.4%6.2%6.4%7.0%7.2%7.2%7.2%7.4%7.4%
20007.4%8.0%8.2%8.0%7.8%8.0%8.0%7.6%7.6%7.4%7.2%7.0%
20016.8%6.2%6.2%6.0%5.8%6.0%6.2%6.0%5.8%5.6%5.0%4.8%
20025.4%5.6%5.4%5.6%6.0%5.8%5.6%5.2%4.6%4.2%3.6%4.0%
20034.2%4.0%3.8%3.6%3.8%3.6%3.0%3.2%4.2%4.4%4.0%4.2%
20044.2%4.2%4.0%3.8%3.8%4.6%5.0%4.8%4.6%4.4%4.2%4.2%
20054.6%4.6%4.6%5.0%5.2%4.8%4.6%4.8%5.0%5.0%5.0%5.4%
20065.4%5.2%5.4%5.6%5.8%6.0%6.0%6.2%6.0%5.8%5.6%5.8%
20075.6%5.6%5.8%5.6%5.6%5.6%6.0%6.2%5.8%5.2%5.2%5.0%
20084.4%4.2%3.6%3.4%3.2%3.8%4.2%4.2%4.2%3.8%3.6%3.4%
20092.4%2.0%2.4%2.6%2.4%2.8%3.4%3.4%3.4%3.2%3.2%3.2%
20103.0%3.4%3.2%3.2%3.4%3.2%2.8%2.6%2.4%2.0%2.0%1.8%
20112.4%2.8%3.0%3.0%3.0%2.8%2.4%2.2%2.0%1.4%1.4%1.6%
20121.4%1.4%1.4%1.4%1.6%1.2%1.2%1.0%1.0%1.2%1.0%1.2%
20131.0%1.2%1.4%1.4%1.2%1.2%1.4%2.0%2.0%2.4%2.0%2.0%
20142.2%2.4%2.2%2.2%2.4%2.2%2.2%2.2%2.2%2.2%2.2%2.0%
20152.2%2.0%1.8%2.0%1.8%2.0%2.2%2.2%2.2%2.0%2.0%2.0%
20162.2%2.2%1.8%1.8%1.8%1.8%1.8%1.4%1.4%1.6%1.6%1.8%
20172.4%2.6%2.4%2.6%2.4%2.4%2.2%2.4%2.4%2.2%2.4%2.6%
20182.6%2.8%3.0%3.2%3.2%3.4%3.4%3.4%3.4%3.4%3.6%3.6%
20193.4%3.2%3.2%3.0%2.8%2.8%2.6%2.2%2.2%1.8%2.0%2.0%
20202.0%2.2%1.8%1.2%0.8%0.6%0.6%0.4%0.4%0.4%0.4%0.6%
20210.6%0.6%0.8%1.0%1.2%1.2%1.2%1.2%1.0%1.0%1.4%1.6%
20221.6%1.6%2.0%2.2%3.0%3.6%3.6%3.8%3.6%4.0%4.8%5.2%
20234.6%4.6%4.4%5.0%4.4%4.2%4.6%5.0%5.0%5.4%5.6%5.8%
20245.2%4.8%5.0%5.2%5.4%5.6%5.4%5.2%4.8%4.4%4.4%5.0%
20255.2%5.4%5.4%5.0%5.0%

* The rates shown for March and April of 1989 exist only for charitable transfers in May or June of 1989 because the donor may elect to apply a rate from one of the preceding two months. See Notice 89-60, 1989-1 C.B. 700, for details. Transfers actually made in March or April of 1989 are not valued using the rates shown above but using the 10% discount rate that applied before the effective date of section 7520. See Treas. Reg. section 20.2031-7A(d).

Before 1989, life estates, remainders, and annuities were valued as follows:

  1. From 12/1/1983 to 4/30/1989, based on a rate of 10 percent and a unisex mortality table that was known as either Table CM (in one publication) or Table LN (in the regulations). You can find tables of factors for single life and term interests, as well as Table LN, at Treas. Reg. § 20.2031-7A(d)(6).
  2. From 1/1/1971 through 11/30/1983, based on a rate of 6 percent and using a different mortality table, also known as Table LN, that showed mortality factors for males and females separately.
  3. From 1/1/1952 through 12/31/1970, based on a rate of 3.5% and U.S. Life Table 38 (which was also gender-specific).
  4. Before 1/1/1952, based on a rate of 4% and a still older mortality table (which was also gender-specific).

See Treas. Reg. § 20.2031-7A for additional information.

Applicable Federal Rates for 2014

HTML Version Copyright 1995-2025 Daniel B. Evans. All rights reserved.


— Short Term Rates for 2014 —

MonthAnnualSemiann.QuarterlyMonthly
Jan-20140.25%0.25%0.25%0.25%
Feb-20140.30%0.30%0.30%0.30%
Mar-20140.28%0.28%0.28%0.28%
Apr-20140.28%0.28%0.28%0.28%
May-20140.33%0.33%0.33%0.33%
Jun-20140.32%0.32%0.32%0.32%
Jul-20140.31%0.31%0.31%0.31%
Aug-20140.36%0.36%0.36%0.36%
Sep-20140.36%0.36%0.36%0.36%
Oct-20140.38%0.38%0.38%0.38%
Nov-20140.39%0.39%0.39%0.39%
Dec-20140.34%0.34%0.34%0.34%

— Mid Term Rates for 2014 —

MonthAnnualSemiann.QuarterlyMonthly
Jan-20141.75%1.74%1.74%1.73%
Feb-20141.97%1.96%1.96%1.95%
Mar-20141.84%1.83%1.83%1.82%
Apr-20141.81%1.80%1.80%1.79%
May-20141.93%1.92%1.92%1.91%
Jun-20141.91%1.90%1.90%1.89%
Jul-20141.82%1.81%1.81%1.80%
Aug-20141.89%1.88%1.88%1.87%
Sep-20141.86%1.85%1.85%1.84%
Oct-20141.85%1.84%1.84%1.83%
Nov-20141.90%1.89%1.89%1.88%
Dec-20141.72%1.71%1.71%1.70%

 — Long Term Rates for 2014 —

MonthAnnualSemiann.QuarterlyMonthly
Jan-20143.49%3.46%3.45%3.44%
Feb-20143.56%3.53%3.51%3.50%
Mar-20143.36%3.33%3.32%3.31%
Apr-20143.32%3.29%3.28%3.27%
May-20143.27%3.24%3.23%3.22%
Jun-20143.14%3.12%3.11%3.10%
Jul-20143.06%3.04%3.03%3.02%
Aug-20143.09%3.07%3.06%3.05%
Sep-20142.97%2.95%2.94%2.93%
Oct-20142.89%2.87%2.86%2.85%
Nov-20142.91%2.89%2.88%2.87%
Dec-20142.74%2.72%2.71%2.70%

Presumption of Undue Influence Overcome

Evidence that the decedent was eighty-nine years old, unable to perform the usual activities of daily living, experienced memory lapses, and exhibited other characteristics of old age and declining mental health were insufficient to overcome presumption of testamentary capacity, but was evidence of weakened intellect and so a presumption of undue influence arose from the execution of a “transfer on death” beneficiary designation naming as primary beneficiary the son to whom the decedent had given a power of attorney and who was involved in all decisions about the decedent’s care.  However, there was sufficient evidence that the decedent exercised independent judgment to overcome the presumption of undue influence.  LaVeglia Estate, 3 Fid.Rep.3d 322 (O.C. Carbon 2013):

Domicile Shown by Actions of Decedent

Decedent was domiciled in Pennsylvania at the time of her death because she had maintained the same home in Philadelphia for more than 40 years, and she had shown by her continued presence and connections to Philadelphia that she still considered it her home, even though she and her husband had purchased a residence in Florida and had signed various documents stating Florida to be their residence.  Perelman Estate, 3 Fid.Rep.3d 307 (O.C. Philadelphia 2013):

Laches in Will Contest Within One Year of Death

Appeal from probate was denied even though the appeal was filed within one year of probate when there was an unexplained delay in the filing of the appeal and the estate was prejudiced by the delay because it was unable to make a charitable distribution within the first year and was required to pay taxes on capital gains as a result, so that the doctrine of laches applied.  Mann Estate, 3 Fid.Rep.3d 302 (O.C. Blair 2013) (Opinion by Doyle, P.J.)

Weakened Intellect not Shown

Proponent of will received substantial benefit under new will because his share of the estate increased from 6% to 35%, and his family’s share increased from 39% to 76%, and proponent had a confidential relationship with the testator, his aunt, because he was one of her trusted advisors and assistants, performing many vital services for her, but contestant failed to present clear and convincing evidence of weakened intellect, only that the testator was aged and physically declining, while medical professionals and testator’s lawyer testified to her continuing mental acuity.  Lista Will, 3 Fid. Rep. 3d 275 (O.C. Philadelphia 2006).