REVENUE RULE 90-104

1990-2 C.B. 33, 1990-52 I.R.B. 5.

Internal Revenue Service
Revenue Ruling

FRINGE BENEFITS; AIRCRAFT VALUATION FORMULA

Published: December 10, 1990

Section 61. - Gross Income Defined, 26 CFR 1.61-21: Taxation of fringe benefits.
Fringe benefits; aircraft valuation formula. For purposes of section 1.61- 21(g) of the regulations, relating to the rule for valuing noncommercial flights on employer-provided aircraft, the Standard Industry Fare Level (SIFL) cents-per-mile rates and the terminal charges in effect for 1990 are set forth. Rev. Rul. 90-43 modified.

For purposes of the taxation of fringe benefits under section 61 of the Internal Revenue Code, section 1.61-21(g) of the Income Tax Regulations provides a rule for valuing noncommercial flights on employer-provided aircraft. Section 1.61-21(g)(5) of the regulations sets forth an aircraft valuation formula to determine the value of such flights. The value of a flight is determined under the base aircraft valuation formula (also known as the Standard Industry Fare Level formula or SIFL) by multiplying the SIFL cents- per-mile rates applicable for the period during which the flight was taken by the appropriate aircraft multiple provided in section 1.61-21(g)(7) and then adding the applicable terminal charge. The SIFL cents-per-mile rates in the formula and the terminal charge are calculated by the Department of Transportation and are revised semi-annually.

The following chart sets forth the applicable terminal charges and SIFL mileage rates for 1990:

EFFECT ON OTHER REVENUE RULING

Rev. Rul. 90-43, 1990-20 I.R.B. 5, is modified.

DRAFTING INFORMATION

The principal author of this revenue ruling is Richard Pavel of the Office of the Assistant Chief Counsel (Employee Benefits and Exempt Organizations). For further information regarding this revenue ruling contact Mr. Pavel on (202) 566-4747 (not a toll-free call).

Rev. Rul. 90-104, 1990-2 C.B. 33, 1990-52 I.R.B. 5.