Originally Posted by
seawolf
Refer to
26 USC §4261(c)(1). Interesting that even
IRS is referring you to Cornell's website for the IRS code.
According to US-based airlines, $0 fare is not considered "any amount paid." No Departure/Arrival Tax. If YQ is charged, this gets triggered.
Up until two years ago, CX awards (JFK-HKG-JFK) when redeemed with AA is $0 fare. No US Departure/Arrival Tax. All this time the HKG Security Surcharge was being absorbed for CX.
At some point since then, CX decided to pass on the Security Surcharge to award passenger triggering a YQ of $6. AA started tacking on US Arrival Tax for HKG-USA oneway and both US Departure/Arrival Tax for US-HKG roundtrips.
My post above is probably not correct and is an oversimplification of the topic.
The IRS
memo seem to suggest whether the international facilities charge (departure/arrival tax) applies in §4261(c) is
dependent on whether the award miles are taxable under §4261(a). Under certain circumstances, they may or may not be taxable.