A Detailed Analysis of § 280F Depreciation Recapture for Business Aircraft

To be eligible to use accelerated or bonus depreciation on a business aircraft, § 280F of the Internal Revenue Code (I.R.C.) generally requires that the aircraft be used at least 50 Percent for business purposes (the “50 Percent Test”). Passing the 50 Percent Test is particularly important for taxpayers seeking to deduct 100 percent bonus depreciation under the Tax Cuts and Jobs Act of 2017. While this test may seem straightforward, it is actually complex and subject to interpretation.

This members-only resource reviews the following topics related to § 280F depreciation recapture:

• the implications of passing or failing the 50 Percent Test, the basic mechanics of the 50 Percent Test and several issues arising under this test
• the recapture calculation that applies if the 50 Percent Test is failed
• the exception in § 280F(c) for lessors in the business of leasing
• the corresponding income inclusion calculation for lessees when the 50 Percent Test is failed.

Review the resource A Detailed Analysis of § 280F Depreciation Recapture for Business Aircraft (PDF)