REVENUE RULE 91-64

1991-2 C.B. 18, 1991-51 I.R.B. 1.

Internal Revenue Service
Revenue Ruling

FRINGE BENEFITS; AIRCRAFT VALUATION FORMULA

Published: December 5, 1991

26 CFR 1.61-21: Taxation of fringe benefits.

Section 61. Gross Income Defined

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 1991 are set forth. Rev. Rul. 90-104 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 Income Tax Regulations provides 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 cumulative terminal charges and SIFL mileage rates:

Period During Which the Flight Was Taken Terminal
Charge		 SIFL Mileage Rates
1/1/91-6/30/91 $31.60 Up to 500 miles = $.1729 per mile
501-1500 miles = $.1318 per mile
Over 1500 miles = $.1267 per mile
7/1/91-12/31/91 $30.19 Up to 500 miles = $.1652 per mile
501-1500 miles = $.1259 per mile
Over 1500 miles = $.1211 per mile

EFFECT ON OTHER REVENUE RULING

Rev. Rul. 90-104, 1990-2 C.B. 33, is modified.

DRAFTING INFORMATION

The principal author of this revenue ruling is Robert Wheeler of the Employee Benefits and Exempt Organizations Division. For further information regarding this revenue ruling contact Mr. Wheeler on (202) 566-4747 (not a toll-free call).

Rev. Rul. 91-64, 1991-2 C.B. 18, 1991-51 I.R.B. 1.