Aviation

Don't fly in the dark with aircraft planning opportunities.

Private aircraft ownership and taxation are complex and involve many federal income tax issues. These issues require coordination with evolving federal aviation regulations and ancillary state and local sales, use, and excise taxes. While the benefits of private aircraft usually outweigh the costs for ultra-high-net-worth individuals, attention to planning and compliance is highly important for aircraft owners and lessors.

Why partner with RS&F?

Given our experience with family offices and ultra-high-net-worth families, our team is well-versed in aircraft ownership and taxation rules, regulations, and nuances. We have worked with numerous clients on their aircraft planning needs, including entity structure, tax requirements, and risk management. The decision to own and/or control aircraft is very complex, and RS&F understands the interplay between aircraft utility, asset protection, and tax mitigation.

Aircraft taxation involves art and science.

Aircraft create potentially significant tax advantages for business use, with sometimes draconian results for excess personal use. Every detail of aircraft operations and compliance affects the deductibility of expenses and the risk of succeeding upon audit. In the private aircraft space, aircraft owners must balance operating flexibility under Part 91 with the potential tax consequences of the desired structure. Strict compliance, recordkeeping, and substantiation are necessary in a highly regulated industry. As a high tax audit risk, owners and operators of aircraft must carefully consider all the various issues associated with aircraft beyond the costs and benefits.

Aviation Services

We provide a variety of aviation planning and compliance services to support clients. Areas of expertise include:

• Business entertainment disallowance calculations and rules
• Buy vs. lease decisions
• Depreciation modeling
• Financing considerations
• Flight log and reporting
• IRS audits
• Personal use considerations, including calculations under the SIFL and general valuation methods
• State sales tax planning for aircraft
• Structuring private aircraft ownership