I received some free tickets from my neighbor to a Dallas Cowboys game. Do the tickets have to be listed?
You have to report all gifts, including tickets to sporting events, that you receive from a single source during the reporting period if the aggregate value of the gifts is more than $350 (amount effective January 1, 2011). When you calculate the value of the gifts to see if they meet the $350 threshold, you can exclude any gifts from that source that are worth $140 or less. For tickets to an event, the aggregate value of all the tickets you receive must be counted as a single gift. For example, if your neighbor gave you four $100 tickets to the game, you must report a $400 gift of tickets on Schedule B, Part II.
By the way, if you’re wondering why the monetary thresholds are so odd, the amounts have been adjusted every three years to keep pace with inflation.
During the year, I attended two receptions sponsored by a trade association. The association did not charge anyone to attend one of the events. The second event was $500 per ticket, but the association didn’t charge me anything. My agency gave me permission to go. Do I have to report my attendance as a gift? If so, how should I determine the value of my attendance?
If your agency told you that you could attend these receptions under an exception to the Standards of Ethical Conduct for Employees of the Executive Branch, you may still need to report the fair market value of the receptions as gifts on your financial disclosure report. The value of each reception will have to be reported, if the fair market value of your attendance at each one is more than $140 and you received gifts aggregating more than $350 from the trade association during the calendar year.
Because no one was charged a fee for attending the first reception, you probably won’t have any idea of the exact value to list. However, you can make a good faith estimate of the retail cost per person of attendance at events such as this, and use that amount as the value on your form. Also, in calculating the value, you may exclude the fair market value of the food and refreshments served at the reception.
For example, let's say that you estimate that the retail value for attendance at the first reception is $125. You also estimate that the actual fair market value of food and refreshments served at the event is $25. The value of the gift that you have to report is $100. Because that amount does not exceed the $140 aggregation threshold, you do not need to include the value of this reception in your calculation of whether gifts from the trade association need to be reported, nor does the reception itself need to be reported on your OGE Form 278.
For the second reception, you know the fair market value of your attendance is $500. In this case, you estimate that the food and refreshments served were worth $50. Therefore, the value you must report is $450, which is over the $350 threshold. You must report this gift on Schedule B, Part II of your OGE Form 278. Also, because you have met the $350 reporting threshold for gifts from this trade association, you must report any other gift you received during the reporting period from the association if the gift's value exceeded $140. (Note: For gifts received in 2010, the reporting amounts were more than $335 for the aggregation threshold and $134 or less for excepted items. The form has not been unpdated to reflect the current threshold amounts.)
Schedule B, Part II instructs me to report travel-related reimbursements and gifts totaling more than $350 (the “aggregation threshold”) from any one source during the reporting period. It also instructs me that I do not have to report any item valued at $140 or less, nor do I even include such an item in calculating the aggregation threshold. Where do these numbers come from?
These amounts are tied under the Ethics in Government Act and OGE regulations to the “minimal value” for reporting foreign gifts under the Foreign Gifts and Decorations Act. The General Services Administration redefines this value every three years. The latest revision occurred this year and was effective January 1, 2011.