Originally Posted by
Andy2
He is extraordinarily biased toward a position that more miles should be taxable and he makes questionable assumptions to validate his bias. We all know that Citi did in fact significantly change its terms and conditions when it stopped issuing 1099s. The customer had to start using a debit card to buy a certain amount of goods and services in order to qualify for the mileage bonus, purportedly reclassifying the bonus from a possible interest payment to a possible nontaxable rebate on the purchased goods and services. That would have been a good place to have reiterated his earlier reference of the two revenue rulings commonly called the "rebate rule" guidance, and discuss whether they work the way Citi thinks they do.
Good point on Citi's change.
The position that miles earned flying on an employer's dollar are income is very mainstream among economists. Non-cash benefits from employment normally need to be counted as income. Otherwise employers could compensate you in
lupins or something to dodge taxes.
I don't think the principle of taxability of employee benefits is debatable. The article addresses the issues of practicality, law (e.g. has Congress carved out an exemption?) and public perception.