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| Attention: | Chief Administrative and Fiscal Officers, Business Managers, and Payroll and Human Resources Officers |
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| Subject: | Calculation of the Taxable Benefit of the Non-Business Use of State-Provided Vehicles, Calendar Year 2015 |
I. PURPOSE
When a state employee commutes in or uses a state vehicle for personal business, certain tax consequences result. The Internal Revenue Service views the personal use as a taxable benefit to the employee and has established guidelines on how to determine how much the dollar value of that benefit would be.
This memorandum supersedes Memorandum 2014-14 and advises agencies of a
change in the rate used in the cents-per-mile method and advises agencies and
employees of a change in the definition of control employee (yearly
compensation).
II. AUTHORITY
Effective January I, 1986, Federal Public Law 99-44 mandates that an employee's personal use of an employer-owned or leased vehicle must be reported to the Internal Revenue Service (IRS) as taxable income. "Personal use" is defined as any non-business use, including commuting from an employee's home to his or her worksite. The term "vehicle" means "any motorized wheeled vehicle manufactured primarily for use on public streets, roads and highways" and generally includes automobiles. Except for certain exceptions as set forth later in this memorandum, all State of Connecticut employees will be subject to taxation on any state vehicle use that is not documented as business use. State agencies will be responsible for implementing the applicable reporting requirements.
The following IRS requirements and other guidelines are set forth to assist agencies in determining those employees whose use of state vehicles is deemed taxable and in reporting the dollar value, by employee, of such benefits.
III. STATE'S VEHICLE USE POLICY
The policy of the State of Connecticut generally prohibits personal use of state-owned/leased vehicles except for home-to-worksite travel as required by the employer. Under the State of Connecticut's written policy, no employee may use the vehicle for personal purposes other than de minimis use (e.g., a stop for lunch between two business appointments or deliveries). Refer to the Department of Administrative Services General Letter No. 115 revised April 2012 as applicable.
IV. VALUATION METHODS
The following methods are to be used in valuing the taxable benefit:
V. CALCULATION OF THE TAXABLE BENEFIT
To calculate the value of his or her commuting or personal miles an employee would:
A. Select the Appropriate Method
Control employees can choose only the lease value or the cents-per-mile methods for calculation ofthe taxable benefit.
A control employee is defined as:
All other employees must use the commuting value method.
B. Perform the Calculation
Example I: Commuting Value Method (used by all non-control employees)
The employee commuted round trips to work for 60 days during the reporting
quarter. The rate of $3.00/day is multiplied by 60 days = $180.00.
Example 2: Control Employee Using Fleet Average Value or Cents-Per-Mile
The employee has been assigned a state vehicle for the first time. She
commutes 20 miles to work round trip for 60 days in the quarterly reporting
period. She may choose one method of valuing the use of the vehicle.
A comparison of the methods follows:
? Fleet Average Value
| $172.50/month for 3 months | = | $517.50 |
| 20 miles/day at 5.5 cents/mile multiplied by 60 days | = | $ 66.00 |
| TOTAL QUARTERLY AMOUNT | $583.50 |
? Cents-Per-Mile
| 20 miles/day at 57.5 cents/mile by 60 days | ||
| TOTAL QUARTERLY AMOUNT | $690.00 |
In this example the lease value method is the less costly. However, once a method is selected, the employee must continue with that method despite any changes in his or her circumstances.
Example 3: Control Employee Using Annual Lease Value
The control employee has been assigned a vehicle for the first time. The vehicle was purchased by his agency and has a Fair Market Value (FMV) of $21,400. He commutes 20 miles to work round trip for 60 days in the quarterly reporting period.
? Lease Value
| $480.90/month for 3 months | = | $1442.70 |
| 20 miles/day at 5.5 cents/mile by 60 days | = | $ 66.00 |
| TOTAL QUARTERLY AMOUNT | = | $1508.70 |
The cents-per-mile valuation rule cannot be used for vehicles with a FMV
exceeding the rate established per IRS Reg. 1.61-21(e)(l)(iii).
Note: When performing the calculation for any method for any vehicle that is not
part of
the DAS on-line reporting program, net out any amount that has been paid to the
state as
reimbursement for personal use. (If the amount paid the state exceeds the
taxable benefit
for the tax year, the benefit equals zero. Credit amounts cannot be carried
forward.)
VI. EXCEPTIONS (Applicable to Eligible Control and Non-Control Employees)
The
following categories of vehicle use are not presently subject to taxation:
1. Qualified Non-Personal Use Vehicles
The term "qualified non-personal use vehicle" is applied to any vehicle that, because of its nature, is not likely to be used more than a very limited (i.e., de minimis) amount for personal purposes.
Refer to Attachment "A" for a listing of "qualified non-personal use vehicles" that fall within this exception with explanatory information concerning the exception requirements for vans and trucks and the narrowly-defined requirements for "law enforcement officer".
2. Overnight Parking ("Garaging") of Vehicle at Approved State-Owned or Leased Facility
Taxation will not apply if an employee uses an approved state-owned or leased facility for the overnight "garaging" of an assigned state vehicle even though such facility was some distance from the employee's worksite and possibly close to his or her home. However, this exception is qualified by three stipulations: (a) a vehicle usage and parking location must make "good business sense" to the employer; (b) overnight parking location must be approved by the employer; and (c) if the driver transports one or more passengers from their home (s) to the worksite, such passengers are subject to taxation on the derived benefits.
3. De Minimis Use of Vehicle
According to Section 1.132-6 of the IRS Regulations, the term "de minimis fringe" means any property or service, the value of which is (after taking into account the frequency with which similar fringes are provided by the employer to the employer's employees) so small as to make accounting for it unreasonable or administratively impracticable.
The regulations give as an example of fringe benefit that is not excludable from gross income: the commuting use of an employer-provided automobile more than one day a month. The regulations also say that "the fact that the commuting use of an employer-provided vehicle more than one day a month is an example of a benefit not excludable as a de minimis fringe does not mean that the commuting use of a vehicle up to 12 times per year is excludable from gross income as de minimis fringe".
VII. REPORTING REQUIREMENTS
Vehicle Usage Fringe Benefit Computation Records
The Department of Administrative Services (DAS) has a program where select officials report their state vehicle usage on-line. Questions regarding this procedure should be directed to DAS, Fleet Operations.
VIII. AGENCY RESPONSIBILITY
Agencies are to notify concerned employees of the preceding requirements and the definition of control employee, and the rate used in the cents-per-mile method.
Agencies must continue to maintain the records necessary to properly determine and report on the dollar value of the vehicle use benefit for the period November 1, 2014 through October 31, 2015.
IX. QUESTIONS
Questions may be directed as follows:
Computation and Benefits: Administrative Services Division, Statewide Fiscal Policy Unit, 860-702-3440;
Payroll Procedures: Payroll Services Division, 860-702-3447;
On-line Home to Office Usage: DAS, Fleet Operations, 860-713-5160.
KL:CH
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