.01 This revenue procedure provides: (1) the maximum value of employer-provided
vehicles first made available to employees for personal use in calendar year
2005 for which the vehicle cents-per-mile valuation rule provided under section
1.61-21(e) of the Income Tax Regulations may be applicable is $14,800 for
a passenger automobile and $16,300 for a truck or van; (2) the maximum value
of employer-provided vehicles first made available to employees for personal
use in calendar year 2005 for which the fleet-average valuation rule provided
under section 1.61-21(d) of the regulations may be applicable is $19,600 for
a passenger automobile and $21,300 for a truck or van.
.01 If an employer provides an employee with a vehicle that is available
to the employee for personal use, the value of the personal use must generally
be included in the employee’s income and wages. Internal Revenue Code
§ 61; Treas. Reg. § 1.61-21.
.02 For employer-provided passenger automobiles (including trucks and
vans) made available to employees for personal use that meet the requirements
of section 1.61-21(e)(1) of the regulations, generally the value of the personal
use may be determined under the vehicle cents-per-mile valuation rule of section
1.61-21(e). However, regulations section 1.61-21(e)(1)(iii)(A) provides that
for a passenger automobile first made available after 1988 to any employee
of the employer for personal use, the value of the personal use may not be
determined under the vehicle cents-per-mile valuation rule for a calendar
year if the fair market value of the passenger automobile (determined pursuant
to regulations section 1.61-21(d)(5)(i) through (iv)) on the first date the
passenger automobile is made available to the employee exceeds a specified
dollar limit.
.03 For employer-provided vehicles available to employees for personal
use for an entire year, generally the value of the personal use may be determined
under the automobile lease valuation rule of section 1.61-21(d) of the regulations.
Under this valuation rule, the value of the personal use is the Annual Lease
Value. Provided the requirements of regulations section 1.61-21(d)(5)(v)
are met, an employer with a fleet of 20 or more automobiles may use a fleet-average
value for purposes of calculating the Annual Lease Values of the automobiles
in the employer’s fleet. The fleet-average value is the average of
the fair market values of all the automobiles in the fleet. However, section
1.61-21(d)(5)(v)(D) of the regulations provides that for an automobile first
made available after 1988 to an employee of the employer for personal use,
the value of the personal use may not be determined under the fleet-average
valuation rule for a calendar year if the fair market value of the automobile
(determined pursuant to regulations section 1.61-21(d)(5)(i) through (v))
on the first date the passenger automobile is made available to the employee
exceeds a specified dollar limit.
.04 The maximum passenger automobile values for applying the vehicle
cents-per-mile and the fleet-average value rules reflect the automobile price
inflation adjustment of Code section 280F(d)(7). The method of calculating
this price inflation amount for automobiles other than trucks and vans uses
the “new car” component of the Consumer Price Index (CPI) “automobile
component”. When calculating this price inflation adjustment for trucks
and vans, the “new trucks” component of the CPI is used. This
results in somewhat higher maximum values for trucks and vans. This change
reflects the higher rate of price inflation that trucks and vans have been
subject to since 1988, and is consistent with the change announced in Rev.
Proc. 2003-75, 2003-2 C.B. 1018 for purposes of calculating depreciation deductions.
See also Rev. Proc. 2004-20, 2004-1 C.B. 642 and 2005-13, 2005-12 I.R.B.
759. For purposes of this revenue procedure, the term “trucks and vans”
refers to passenger automobiles that are built on a truck chassis, including
minivans and sport utility vehicles (SUVs) that are built on a truck chassis.
.01 Maximum Automobile Value for Using the Cents-per-mile Valuation
Rule. An employer providing a passenger automobile for the first time in
calendar year 2005 for the personal use of any employee may determine the
value of the personal use by using the vehicle cents-per-mile valuation rule
in section 1.61-21(e) of the regulations if its fair market value on the date
it is first made available does not exceed $14,800 for a passenger automobile
other than a truck or van, or $16,300 for a truck or van. If the fair market
value of the passenger automobile exceeds this amount, the employer may determine
the value of the personal use under the general valuation rules of regulations
section 1.61-21(b) or under the special valuation rules of section 1.61-21(d)
(Automobile lease valuation) or section 1.61-21(f) (Commuting valuation) if
the applicable requirements are met. See Rev. Proc. 2003-75 for guidance
on determining the maximum value of passenger automobiles first made available
during calendar year 2003, and Rev. Proc. 2004-20 for guidance on determining
the maximum value of passenger automobiles first made available during calendar
year 2004.
.02 Maximum Automobile Value for Using the Fleet-Average Valuation Rule.
An employer with a fleet of 20 or more automobiles providing an automobile
for the first time in calendar year 2005 for the personal use of any employee
for an entire year may determine the value of the personal use by using the
fleet-average valuation rule in regulations section 1.61-21(d)(5)(v) to calculate
the Annual Lease Values of the automobiles in the fleet. The fleet-average
valuation rule may not be used to determine the Annual Lease Value of any
automobile if its fair market value on the date it is first made available
exceeds $19,600 for a passenger automobile other than a truck or van, or $21,300
for a truck or van. If all other applicable requirements are met, an employer
with a fleet of 20 or more vehicles consisting of passenger automobiles other
than trucks or vans as well as trucks and vans may use the fleet-average valuation
rule as long as none exceeds its respective maximum allowable value. If the
fair market value of any passenger automobile in the fleet exceeds these amounts,
the employer may determine the value of the personal use under regulations
section 1.61-21(f) (Commuting valuation) or the general valuation rules of
section 1.61-21(b), or may determine the Annual Lease Value of such automobile
separately under the automobile lease valuation rule of section 1.61-21(d)(2)
if the applicable requirements are met.
SECTION 4. EFFECTIVE DATE
This revenue procedure applies to employer-provided passenger automobiles,
trucks or vans first made available to employees for personal use in calendar
year 2005.
SECTION 5. DRAFTING INFORMATION
The principal author of this revenue procedure is Frederick L. Wesner
of the Office of Division Counsel/Associate Chief Counsel (Tax Exempt &
Government Entities). For further information regarding this revenue procedure,
contact Frederick L. Wesner at (202) 622-6040 (not a toll-free call).
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