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New fringe benefit regulations make useful changes to car and plane valuation rules.

In final regulations published December 30, 1992 (at 57 Fed. Reg. 62192), the Internal Revenue Service and United States Department of the Treasury made several simplifying changes to the fringe benefit valuation and notification rules. These changes, which will generally prevent employers' minor errors in using these rules from creating major problems on audit --

* retroactively eliminate the requirement that employees must be notified about the special valuation rule used by the employer in valuing personal travel on company cars and planes;

* clarify the conditions under which the special valuation rules may be used (including on corrected Forms W-2 and 1099); and

* clarify the conditions under which special valuation rules may be applied to security protection (including transportation in employer-provided cars and planes) provided to certain employees.

These changes are included in final regulations governing both security protections provided to government workers and fringe benefits provided to volunteers for tax-exempt organizations. The Treasury Department's changes respond favorably to comments on the fringe benefit regulations that have been submitted over the past two years by the Tax Executives Institute and others on behalf of numerous companies. These comments effectively communicated concerns about the prior regulations' limitation on use of the special valuation rules, including the over-complex employee notification requirements and an apparent prohibition on corrections, following an IRS audit, of prior years' inadvertent mistakes in applying the special valuation rules.

I. Retroactive Elimination of Car/Plane Valuation Notices

A. Prior Law

Prior to the issuance of the amended final regulations, the special fringe benefit valuation rules that apply to employees' taxable use of company-provided cars, planes, and cafeterias have since 1985 contained detailed employee notification requirements. These valuation notices were required to explain to employees:

* the valuation rules used by the employer,

* the substantiation requirements applicable to employees' business use of company cars or planes, and

* the penalties applicable to any failure to comply with these substantiation requirements.

Written, dated notices were required to be provided by January 31 of the year in which the benefit was first provided to the employee (or, if later, within 30 days after the benefit was provided).(1*) After 1988, employers that failed to provide timely valuation notices to employees were prohibited from using the special valuation rules, unless they corrected the notification error by collecting affidavits from employees by January 31 of the year after the year in which the benefit was first provided, attesting that the employees already knew all the information that should have been provided in the valuation notice.(2)

B. Reasons for Change

Although IRS payroll agents apparently have not yet been auditing employers' compliance with notification requirements, many employers have been concerned that inadvertent failures to provide valuation notices to some workers would have required employees' personal use of company cars and planes to be valued, on audit, under fair market valuation (FMV) valuation rules. In the case of airplanes, these values (which approximate the cost of chartering the aircraft) can be 50 times higher than the special "SIFL" valuation rules provided in the fringe benefit regulations. Taxpayers argued that the employee notices proved an unnecessary paperwork burden, and that the penalty for failure to provide notice was both too harsh and imposed unfairly on employees, even though the failure to notify would have been an employer mistake.

C. Amended Final Regulations

In response to these criticisms, Treasury eliminated the employee notification requirement, retroactive to 1985, by deleting both Treas. Reg. Sections 1.61-21(c)(3)(ii) (applicable after 1988) and 1.61-2T(c)(3)(ii) (applicable from 1985 through 1988) from the current regulations. Employers are no longer required to inform employees about the special rules used in valuing employees' personal use of company cars and planes, or about the substantiation rules that must be satisfied to support employees' business use of such vehicles. Moreover, any failure by an employer to provide such notices in prior years will not trigger penalties of increases in the amounts of income imputed to employees.

D. Withholding and Reporting Notices for Cars and Noncash Fringe Benefits Are Still Required

These new final regulations do not change the requirement that employers inform employees (apparently, on an annual basis) about (1) the special withholding rules elected by the employer that apply to vehicles and (2) about the special reporting rules applicable to "noncash fringe benefits," as defined in Announcement 85-113, 1985-31 I.R.B. 31. That Announcement requires every employer to notify its employees if the employer elects not to withhold income taxes with respect to any "vehicle fringe benefits." Notices are also required if the employer elects to use a special fiscal-year rule for reporting any non-cash fringe benefits provided to the employee.

Any notices exempting vehicles from income tax withholding must be mailed (or posted on an employee bulletin board) by January 31st of each year in which the special vehicle withholding rules are to be applied or, if later, within 30 days of the provision of the benefit to the employee.(3) Any notices with respect to use of the special accounting period rule must be provided at or near the time Forms W-2 for the year are provided to employees.(4) No notice of either type of election has ever been required to be provided to the IRS.

The IRS has never announced any penalty for failure to provide these special withholding and reporting notices required by Announcement 85-113. If these notices are ever ruled to be a precondition to use of either the withholding exemption under section 3402(s) for vehicles, or the special accounting period rules developed as part of the year-end withholding rules mandated by the Recordkeeping Repeal Act of 1985,(5) however, IRS payroll agents could assess penalties on employers for failure to withhold and report at the time each particular noncash fringe benefit is provided.

II. Adoption of "Second Chance" Rule Allowing Use of Safe Harbor Valuation Rules on Corrected Forms W-2 and 1099

A. Prior Law

The temporary regulations in effect from 1985 through 1988 and the final regulations in effect after 1988 contained an additional restriction (separate from the valuation notice requirement) on use of the special valuation rules. The additional restriction, which was designed to encourage employers to elect to use these rules and to use them correctly, became known as the "no second chance" rule. More specifically, if an employee's personal trip in an employer-provided plane or car had been undervalued (under the special valuation rules) or excluded entirely from the employee's income (either by oversight, or by misapplication of a working condition fringe exclusion) and the mistake was discovered on audit by the IRS, the value of the fringe benefit had to be determined under general FMV valuation rules (which, as noted above, require use of charter values, for airplane travel).(6)

B. Reasons for Change

As was true with respect to the valuation notice requirement, no instances have yet been reported of any IRS payroll agent prohibiting an employer from using the special valuation rules because of the "no second chance" rule. Nevertheless, employers have been concerned that their inadvertent mistakes in applying the special valuation rules, or an oversight of a particular personal trip, would have required employees' personal use of company cars and planes to be valued, on audit, under the FMV valuation rules. Many of these concerns were raised in taxpayers' comments on changes proposed in 1990 and 1991 in the fringe benefit regulations, which dealt with security-related transportation provided to government workers and to employees who need protection for commutes home late at night or in dangerous neighborhoods. Taxpayers argued that all of the special valuation rules should be available for use, even if an employer neglected to include the proper safe-harbor value on an employee's original (or amended) Form W-2 or 1099 and the mistake was discovered on audit.

C. Amended Final Regulations

In response to these criticisms of the "no second chance" rule, the Treasury has attempted, on a prospective basis, to "clarify the requirements for using the special valuation rules."(7) Under this clarification, effective for benefits provided after 1992, satisfaction of any of the following four alternative preconditions is sufficient to permit employers and employees to use the special valuation rules:(8)

1. The employer must treat the value of the benefit as wages for reporting purposes within the time for filing returns for the taxable year (including extensions) in which the benefit is provided.(9)

2. Whether or not the employer has used a special valuation rule on a Form W-2 or Form 1099, the employee must include the value of the benefits in income under the special valuation rules within the time for filing federal income tax returns for the taxable year (including extensions) in which the benefit is provided.(10)

3. The employee is not a "control employee" within the general definition of that term in Treas. Reg. Sections 1.61-21(f)(5) and (6) (meaning, for private-sector employers, employees earning over $100,000 (inflation-adjusted), officers earning over $50,000 (inflation-adjusted), directors, and one-percent owners).(11)

4. The employer demonstrates that it attempted in good faith to treat the benefit correctly for reporting purposes.

In essence, these rules ensure that an employer can always use the special valuation rules for benefits provided after 1992, even if it has not used the rules correctly within the deadlines for filing information returns or employees' individual federal income tax returns. The special rules may be used so long as (a) the employee is not a "control employee" or (b) the employer made a good-faith mistake in valuing the employee's benefit.

These sensible standards provide welcome relief for any employers who have developed detailed recordkeeping and reporting systems for imputing income with respect to personal use of company cars and planes, but who may occasionally (but inadvertently) overlook a particular car ride or plane flight. A mistake could easily arise, for example, in the case of airplane flights provided to company guests, who are not "control employees" with respect to the provider of the flight and whose names and other identifying information might not even be recorded on the flight logs. Under the new standards for using the special valuation rules, if this reporting error were ever discovered on audit, the amount of the adjustment in imputable but unreported income would be limited to the SIFL rate for a non-control employee (which is far less than the charter value of the flight).(12)

D. Questions About the Amended "Second Chance" Rule

Although the Treasury unquestionably intended that these new rules would "clarify" the conditions under which special valuation rules can be used, questions have arisen about the interpretation of this amendment of the old "no second chance" rule. Informal answers to these questions, provided by a Treasury staff attorney responsible for the new final regulations, are discussed below.

1. Application of "Second Chance" Rule to Pre-1993 Benefits. Because the four new alternative "conditions" on use of the special valuation rules apply only to post-1992 benefits, may taxpayers assume that the special valuation rules can always be elected for benefits provided prior to 1993, even if a mistake in using the rules (including complete failure to use the rules) is discovered on audit? If so, why were no changes made in Treas. Reg. Sections 1.61-21(c)(5), (b)(6), and (g)(13)(ii) (additional explanations of the "no second chance" rule applicable to post-1988 benefits) or to Treas. Reg. Sections 1.61-2T(c)(5), (b)(5) and (g)(11) (the 1985-1988 version of the "no second chance" rule)?

A Treasury attorney has stated that the four new alternative conditions on use of the valuation rules are intended to replace the prior law "no second chance" rule. Moreover, even though the new final regulations apply only on a prospective basis, the Treasury did not intend to imply that it would necessarily prevent these four new alternative conditions on the use of the special valuation rules from applying to pre-1993 benefits. Nevertheless, both the failure to amend (or repeal) the regulations containing the "no second chance" rule and the stated prospective effective date of the new tests make it unclear exactly when the Treasury will permit the special valuation rules to be used even if good-faith mistakes in using the rules (or unintentional failures to use the rules) are discovered on audit. To further clarify the conditions under which the special valuation rules can be elected both for post-1992 and pre-1993 benefits, technical corrections to these new final regulations may be needed. Indeed, such amendments are already under consideration at Treasury.

2. Employer's Initial Use of Special Valuation Rules. Under the first of the alternative conditions on use of the special valuation rules in new Treas. Reg. Section 1.61-21(c)(3)(ii)(A), was it intended that the employer must use the special valuation rules, when it "treats the value of the benefit as wages for reporting purposes . . ." or could an employer value a benefit under the general valuation rules and elect the special valuation rules at a later date?

A Treasury attorney has stated that this first condition was intended merely to require employers to report the fringe benefits as income in filing the employee's information return. Lower values (under the special valuation rules) may therefore be elected by such an employer in later years.

3. Deadline for Employer's First Use of Special Valuation Rules. Applying the first two alternative conditions on use of the special valuation rules in new Reg. Sections 1.61-21(c)(3)(ii)(A) and (B), what is the final deadline for an employer to use a special valuation rule on an information return for a control employee who would not independently know to use the special valuation rule in filing his own return? (Assume for this purpose that the "good faith" exception outlined above does not apply.)

A Treasury attorney has advised that the applicable deadline is either the extended deadline for filing information returns for the taxable year in which the benefits were provided (i.e., March 30 of the year after the benefits were provided), or the extended deadline for filing individual income tax returns (i.e., August 17), provided that the employee reports the same special value on his own income tax return. This August 17 deadline for correcting information returns was not specifically contemplated by the drafters of the new regulations, but technically it appears to be available. Significantly, the mere fact that the employer corrected the information returns would presumably in any event make the employer eligible for the "good faith" exception.

4. Definition of "Control Employee" for Whom the Special Valuation Rules Can Always Be Elected. May an employer always elect to apply the aircraft special valuation rules to any employee who is not a "control employee" for purposes of those special rules, even if the individual may be a "control employee" for purposes of the automobile special valuation rules?

A Treasury attorney has stated that a cross-reference to the special definition of "control employees" in Treas. Reg. Sections 1.61-21(g)(8) and (9) will be added by technical correction to new Treas. Reg. Section 1.61-21(c)(3)(ii)(C) to clarify that the "non-control employee" SIFL rates can always be elected for employees who are not control employees under the aircraft valuation rules.

5. Proof of "Good Faith." How will an employer be able to prove ". . . a good faith effort to treat the benefit correctly for reporting purposes," within the meaning of new Treas. Reg. Section 1.61-21(c)(3)(ii)(D)?

The new regulations do not provide any examples of a "good faith" mistake. Treasury and IRS attorneys have informally advised, however, that if unintentional errors are made in valuing personal use of employer cars and planes, or even if certain car usages or plane flights are overlooked or misclassified as "business usages," an employer should be able to satisfy this "good faith" test. The employer simply needs to show that it attempted to apply the rules correctly and that it established reasonable procedures for tracking and valuing employees' fringe benefits. This test could not be satisfied, however, by an employer who has not even attempted to value the fringe benefits provided to some or all of its control employees.

III. Changes to "Security Exclusion" Rules Primarily Affect Government Employees

A. Overview of Security Exclusion Rules

Under a special provision of the "working condition fringe" exclusion, certain benefits provided by an employer for the "security of employees" are excludable from the employees' gross incomes, if a series of tests set forth in Treas. Reg. Section 1.132-5(m) are satisfied. First, the employer must prove a "bona fide need" for security protection for the employee, based on threats of death, kidnapping, or serious bodily harm either to the employee receiving the protection or to a "similarly situated employee" of either the same employer or another unrelated employer. In addition, if security protection is provided on a less than 24-hour basis, any private-sector employer must obtain and comply with an "independent security study" from an outside consultant, which details the type of security protection needed. Under the new final regulations, which finalize regulations proposed in September 1991, government employers may conduct internal security studies.

Even after the applicability of a security exclusion has been proven, the employee receiving the security protection remains taxable for his personal use of the transportation. In the case of automobiles provided for security reasons, private-sector employees must include in income the value of the transportation the employee would have used, absent the security concerns. For example, a private-sector employee travelling in a chauffeured limousine for security reasons is still taxable on what it would have cost to lease that vehicle, without the driver and the bulletproof glass (i.e., generally $500 plus 25 percent of the original cost of the car, times the employee's percentage of personal use of the car, plus 5.5 cents per personal mile driven if the employer provides gasoline).

Under the new final regulations, government employees eligible for the security exclusion must include in income a maximum of $3 per day (the value of a round-trip commute), even if the vehicle is used for more than merely commuting purposes.

In the case of travel in non-commercial aircraft that is provided for security reasons, both private-sector and government employees must include in income a special safe harbor value for a personal flight (referred to as the "200 percent of SIFL rate"). Currently, the value of a personal airplane trip by a control employee needing security protection (which applies equally to any flight trip by the employee's spouse and dependent children travelling with the employee) ranges from approximately 100 percent to 150 percent of the comparable commercial coach fare (using the 7-day advance purchase rate).

B. The New Regulations Require All Employers to Periodically Re-Evaluate the Employee's Need for Security Protection

The new regulations restate the general rules governing the security exclusion, both (1) to emphasize that "a generalized concern for an employee's safety is not a bona fide business-oriented security concern," and (2) to require both private-sector and government employers to "periodically evaluate the situation for purposes of determining whether the bona fide business-oriented security concern still exists."(13)

These revisions to the general security exclusion rules should not present any problems for most private-sector employers currently using the rules, because they merely emphasize that the security exclusion should be used only in those cases (and for the length of time) that legitimate need for security protections can be demonstrated. These changes also do not require private-sector employers to obtain new security studies each time the need for an employee's security protection is re-evaluated. The security studies that must be prepared by government employers, however, are required by the new final regulations to include --

. . . an estimate of the length of time protective services will be necessary, and the extent to which employer-provided transportation may be necessary during the period of protection.(14)

By analogy to this requirement, any independent security studies obtained by private-sector employers in the future should, if possible, specify not only the type of security protection needed, but also the period of time over which the protection should be provided.

C. The New Regulations Unintentionally Require the "Similarly Situated Employee" with Security Concerns to be Employed by the Same Employer as the Employee Receiving the Security Protection

The general definition of a "bona fide business-oriented security concern," as revised in 1989, had allowed an employer to consider not merely threats of terrorism, death, kidnapping, or serious bodily harm made against the employee receiving the protection, but also threats made against a similarly situated worker at either the same company or other unrelated companies.(15) The revised definition refers to "a similarly situated employee ... of the employer," implying that the threats must have been made against an employee of the same employer providing the protection.(16)

According to a Treasury attorney responsible for these regulations, this change was not intended to override the sensible expansion of the "bona fide security concern" test that was adopted in 1989. For example, if all but one of the major companies in a particular geographic area receive death threats against each company's president, the company that did not receive a death threat nevertheless may have extremely legitimate security concerns about the life of its president. Similarly, if all but one of the governors attending a particular convention receive kidnapping threats, the State whose governor was not threatened nevertheless should be entitled to provide security protections to its governor during the convention. To clarify that cases like these would be viewed as qualifying for the security exclusion, the Treasury attorney has informally agreed to consider issuing a technical correction to the new regulations, to permit a "bona fide security concern" to be based upon threats received by similarly situated employees of unrelated employers.

D. The New Regulations Continue to Require Private-Sector Employers to Obtain Independent Security Studies

Although the new regulations allow all government employers to conduct internal security studies (performed by responsible individuals), no change was made in the requirement that private-sector employers must hire outside consultants to perform any security study.(17) This security study requirement is waived only if 24-hour security protection is provided.

E. Need for Some Security Studies to Be Employee-Specific

According to the general rules governing security studies (which were not amended by the new regulations), any security study performed by an employer must relate either to the employee or "a similarly situated employee of the employer." This "similarly situated employee" requirement differs from the one outlined in part III.C. In brief, although a security concern may be generated by a threat on a similarly situated employee of the same employer or an unrelated employer, any security study (which must be obtained, in order for the security exclusion to apply) must be obtained by each employer providing security protection, and it must discuss the security protections to be provided to a specifically identified employee (or employees). That security study can then be used by the employer to justify the security protections extended either to the employee(s) cited in the security study, or to any similarly situated employee of the same employer.

For example, assume that a terrorist threatens to bomb the executive offices of all but one of the major companies in a particular city. All of the major companies in that city should be treated as having a "bona fide security concern" for their executives and, thus, each of the companies could hire a security consultant to perform a security study covering the executives and other endangered employees at each of the companies. If one of those companies hires a new executive after its security study has been performed but while the security threat still exists, that new (but "similarly situated") employee should be treated as being covered by the existing security study.

In contrast to these general rules applicable to security studies performed by independent consultants, slightly different special rules (finalized in the new regulations) permit governments to perform internal security studies. These special rules require any internal government security studies to be employee-specific. This was accomplished by requiring these government security studies to be conducted "with respect to a particular government employee."(18)

F. No Change in Valuations of Security Protections Provided to Private-Sector Employees

Despite the criticisms raised with respect to the 1991 proposed regulations for valuing security protections for government employees (which argued that the proposal created a "double standard" for valuing benefits provided to government versus private-sector employees), the new regulations make no changes in the special valuation amounts applicable to security protections provided to private-sector employees. The new final regulations do clarify, however, that government employees must include the same amount in income as do private-sector employees for any personal flights on non-commercial aircraft provided for security reasons.(19)

IV. Conclusion

These new fringe benefit regulations provide welcome relief from both the valuation notice requirements and the "no second chance" rule. Under this change, employers will be permitted in many more cases to elect to use the special valuation rules, without the paperwork burdens connected with valuation notices or fear that inadvertent mistakes in applying the special valuation rules would prevent subsequent use of these rules if information reporting errors are ever discovered on audit. These regulations are an excellent example of a prompt and carefully considered response by both the Treasury and the IRS to complaints about reporting burdens that were raised by concerned employers. The attorneys responsible for these regulations deserve credit, and thanks, from all the employers and employees who benefit from the new rules.


(1) See Treas. Reg. Sections 1.61-21 (c)(3)(ii) and 1.61-2T(c)(3)(ii). Annual notices were not required, so long as any employee using an employer-provided car or plane for personal reasons had been notified at least in the initial year of personal use of the valuation method elected by the employer.

(2) See Treas. Reg. Section 1.61-21(c)(3)(ii)(D). This correction procedure, as well as the penalty for failure to provide the valuation notices, was not contained in the pre-1989 regulations.

(3) Announcement 85-113, Section 5.

(4) Announcement 85-113, Section 6.

(5) See H.R. Rep. No. 99-67, at 17-18 (1985). No employee notices are required by Announcement 85-113, if the employer elects year-end withholding on non-cash fringe benefits, although many employers inform employees of this election, in order to avoid year-end surprises for employees.

(6) For the post-1988 version of the "no second chance" rule, see Treas. Reg. Sections 1.61-21(c)(5) (general rule) and 1.61-21(b)(6) and (g)(13)(ii) (special rules for airplane valuation). For the 1985-1988 version of the "no second chance" rule, see Treas. Reg. Sections 1.61-2T(c)(5) (general rule) and 1.61-2T(b)(5) and (g)(11)(i) and (ii) (special rules for airplane valuation).

(7) See 57 Fed. Reg. 62192 (December 30, 1992) (Preamble to the new regulations).

(8) These four conditions are outlined in new Treas. Reg. Section 1.61-21(c)(3)(ii), which replaces the prior employee notification requirements. As currently drafted, these conditions apply only to benefits provided after 1992. Treasury reportedly is considering making these conditions electively available for pre-1993 benefits as well.

(9) This condition, as drafted, raises several questions concerning whether the employer must use a special valuation rule on the information return as originally filed, or whether corrections could be made to include the values of omitted benefits, up until a deadline which may be even later than 30 days after the last day of February of the year after the benefit was provided. (March 30 is the filing deadline for all information returns, if a filing extension has been timely requested on Form 8809.)

(10) In general, under the various "consistency rules" governing use of the special valuation rules, an employee may use the special valuation rules only if the employer uses the rules and must report the same value as reported by the employer. Under a separate change to the new regulations, however, effective for benefits provided after 1992, employees are allowed to use the special valuation rules, even if the employer has not used the rules (or has not used them correctly). This can be done only if (a) the employee reports the special value on a timely filed federal income tax return; (b) the employee is not a control employee, or (c) the employer made a good-faith mistake in applying the valuation rules. See new Treas. Reg. Section 1.61-21(c)(2)(ii).

(11) These inflation-adjusted limits for 1992 are $124,690 and $62,345. (The inflation-adjusted limits applicable in 1993 are $128,490 and $64,245 (see IR 93-2, January 15, 1993). Apparently by oversight, the new regulations do not include a reference to the special definition of "control employees" applicable for purposes of the special airplane valuation rules in Treas. Reg. Sections 1.61-21(g)(8) and (9).

(12) The SIFL rates could be elected because, under this example, the employee is a non-control employee. Even if the employee were a control employee, the SIFL rates still could be used to adjust the amount of imputed income, assuming that the company met the "good faith" tests, and shows that its error was only inadvertent.

(13) See Treas. Reg. Section 1.132-5(m)(2)(i).

(14) See Treas. Reg. Section 1.132-5(m)(2)(v)(B).

(15) See Treas. Reg. Sections 1.132-5(m)(2)(v)(A) through (D), prior to its revision by the December 30 regulations (referring specifically to "a similarly situated employee of an employer").

(16) See Treas. Reg. Section 1.132-5(m)(2)(i)(A), as revised by new regulations.

(17) Treas. Reg. Section 1.132-5(m)(2)(iv)(A) (applicable after 1988). See also Treas. Reg. Section 1.132-5T(m)(2)(iv)(A) (applicable prior to 1989).

(18) See Treas. Reg. Section 1.132-5(m)(2)(v), first sentence, as revised by new regulation to add the adjective "particular" to modify "employee." See also new Treas. Reg. Sections 1.132-5(m)(2)(v)(B) and (D) (which require any government study to refer to "the employee"). See also Preamble to the new regulations, which states that these amendments to the government security rules "clarify that the independent security study must be performed with respect to each employee who is provided protection . . . ."

(19) See Treas. Reg. Sections 1.132-5(m)(1), (m)(3)(iv), and (m)(6).
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Author:Hevener, Mary B.
Publication:Tax Executive
Date:Mar 1, 1993
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