11, 2002) (acquiescence relating to whether a taxpayer that provides vacation flights to employees and includes the value of the flights in the employees' income using the SIFL
rates in Treasury regulations section 1.61-21 (g) may then deduct the full (higher) cost of providing the flights, notwithstanding the deduction disallowance provisions of section 274(a)).
Based on Fitch's recovery analysis, debt at SIFL
and Coral-US Co-Borrower have been assigned 'RR4' Recovery Ratings, which represent an average recovery prospect in the case of default, resulting in the same issuance ratings as the group IDR of 'BB-'.
Documents from the SIFL
show that the SIFL
thought Turner bought the team.
The use of SIFL
valuation guidelines was announced in some detail in a Senate Finance Committee report (152) accompanying 1985 legislation principally concerned with eliminating a requirement of contemporaneous recordkeeping of business automobile usage.
S properly determined the standard industry fare level (SIFL
) value of each personal flight under Regs.
Actually, right now there's a dude, Liam Lynch, who used to do a puppet show called Sifl
& Oily on MTV.
He co-created a cult American short animation called Sifl
And Olly, which gained cult status when aired on MTV in America.
Under Treasury Regulations section 1.61-21(g)(5), the value of a flight is generally computed using the three-step standard industry fare level formula (SIFL
A flight's value is figured by multiplying the Standard Industry Fare Level (SIFL
) mileage rate by an aircraft-assigned constant value (these constants vary with the weight of the aircraft and the employee's status as a controlling or noncontrolling employee) and adding a terminal charge.
Some of what Ward claims is backed up by the fact that the SIFL
apparently thought Turner bought the team from Ward since a letter was sent by SIFL
commissioner Gary Tufford to some 600 season ticket holders, saying that Turner (not Ward) should be contacted if they wanted a refund on their season tickets.
Finally, transactional lawyers, too, may be unaware of the requirements of national and international registries that influence the purchase and sale of airplanes, not to mention sales and use tax, head tax and segment fees, depreciation and bonus depreciation, SIFL
rules and other tax-related matters that are frequently a consideration in many areas of aviation law.
Indeed, the Proposed Regulations reflect a continuing vigorous effort by the IRS to penalize taxpayers for the entertainment use of aircraft by their executives (and others also deemed to be "specified individuals"), rather than implementing workable disallowance rules designed to address the primary purpose for using the aircraft, the costs fairly allocable to entertainment use, and the discrepancy between the income reported for personal flights (when valued under the standard industry fair level, or SIFL
, rules) and deductibility of the costs associated with providing such taxable fringe benefits.