FET on Fractionally Owned Aircraft The Internal Revenue Service holds that commercial federal excise tax can be due in management fees.
THE KEY ELEMENTS in any fractional aircraft program as outlined in FAR Part 91 Subpart K are co-ownership, a dry lease exchange and common aircraft management. Back in the early to mid-'90s the Internal Revenue Service (IRS) issued Technical Advice Memorandum (TAM) 9314002 and Private Letter Ruling...
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