There's a raging controversy over this, as Citibank gave American
Airlines miles as a promotion for opening new accounts, then sent
customers 1099's valuing the miles at 2.5 cents per mile.
Assuming (as seems sensible) that the miles are considered bonus
interest on an account, what should the value be.
Let me give some parameters:
a) If you redeem the miles optimally, you can potentially get a value
of 5 cents per mile, say 100,000 miles for an international business
class ticket that would cost $5000. (But how many people would buy it
for cash if they had to pay $5000?)
b) If you buy miles from airlines directly, they usually cost between
2.5 cents and 3 cents per.
c) If you want to redeem them for merchandise, gift cards, or travel
not directly related to a frequent flier award, they usually can be
redeemed for value of 0.6 to 1.0 cents, occasionally 1.25 cents.
d) Black-market transactions generally take place at 1.0 to 1.5 cents
per mile.
e) In practice, when used for award tickets, the value can vary
greatly. At one extreme, I once got a last-minute ticket on a high-
fare route that would have cost $2000 for 25,000 miles, a value of 8
cents per mile - but I wouldn't have bought the ticket for $2000. I
have seen other times that a $100 ticket would take 50,000 miles, a
value of 0.2 cents - but nobody would buy that ticket with miles of
course.
f) Bulk purchasers (like Citibank) probably pay about 1 cent per mile.
g) Under the terms and conditions of the programs, miles remain the
property of the airline. As such, you could argue that there is no
constructive receipt until you redeem them, because the airline could
revoke them at any time. (This has a bit of a tinge of a tax
protester argument, but I think it's a good deal stronger that arguing
that if you're not paid in gold, it's not income. I'm not sure I'd
actually try it. But considering that Citi was giving American
Airlines miles, and that AA is bankrupt, it makes an interesting
argument.)
So what should the miles be valued at, and what is the recourse for a
taxpayer who got a 1099 that overvalued the miles?
Also, assuming Citi bought them for 1 cent, what are the implications
to Citi? Do they get a deduction for 2.5 cents? Do they report the
difference between the purchase price and 2.5 cents as income? Is
this just a con game to pump up their profits and make their customers
pay the taxes on them?
--
<< ------------------------------------------------------- >>
<< The foregoing was not intended or written to be used, >>
<< nor can it used, for the purpose of avoiding penalties >>
<< that may be imposed upon the taxpayer. >>
<< >>
<< The Charter and the Guidelines for submitting posts >>
<< to this newsgroup as well as our anti-spamming policy >>
<< are at
www.asktax.org. >>
<< Copyright (2011) - All rights reserved. >>
<< ------------------------------------------------------- >>