IRS to Kickoff Audit Campaign Focused on Business Aircraft Users
What You Need to Know
Key takeaway #1
Individual and corporate taxpayers that improperly reported personal aircraft use as business use may face increased taxable income and penalties and/or denial of deductions.
Key takeaway #2
Corporate taxpayers that allocated the affiliated individual’s use of the corporate jet as business use may be denied deduction of such use.
Key takeaway #3
Taxpayers may wish to preemptively audit the prior deductions and, if the target of an IRS audit, seek advice from tax professionals with specific expertise in business aviation tax and IRS audits.
Client Alert | 1 min read | 02.29.24
Last week, the IRS announced plans to begin a campaign to audit personal use of business aircraft. The audits will focus on whether large corporations, partnerships and high-and ultra-high net worth aircraft owners have properly reported their business and personal aircraft usage for tax purposes, with a particular focus on ensuring that owners are only taking deductions to which they are entitled. Given the value of an aircraft, the amount of a deduction for aircraft related expenditures on a given taxpayer’s return can be in the tens of millions of dollars, and with more than 10,000 corporate jets operating in the U.S., IRS Commissioner Daniel Werfel recognized that much is at stake with this campaign. The audit campaign is expected to focus initially on multinational and domestic corporations and complex partnerships but is expected to expand from there.
Contacts
Insights
Client Alert | 5 min read | 06.01.26
California Court Upholds Insurer’s Duty to Defend After Covered Claim Is Dismissed
On April 30, 2026, the U.S. District Court for the Northern District of California issued a significant ruling in an insurance coverage dispute between a commercial general liability insurer and its policyholder. The decision addresses several critical issues in insurance law, including the scope and continuity of the duty to defend and the standard for insurer reimbursement of defense costs in mixed-claim actions. The court ruled largely in favor of the insured, SVO Building One, LLC ("SVO"), and the matter now heads toward settlement or trial on SVO's remaining counterclaims.
Client Alert | 2 min read | 05.29.26
California Assembly Passes AB 1776, Sending Major Antitrust Bill to the Senate
Client Alert | 5 min read | 05.29.26
Clover Insurance v. HHS: S.D. of Georgia Holds 20 Star Ratings Measures Unlawful
Client Alert | 3 min read | 05.29.26




