Does restored 100% bonus depreciation make aircraft ownership the right choice?

It changes the tax analysis, not the mission analysis. On 14 January 2026, Treasury and IRS issued Notice 2026-11 addressing the permanent 100% additional first-year depreciation provision for eligible property acquired and placed in service after 19 January 2025. The notice provides interim guidance following the 2025 legislation. (irs.gov)

For an aircraft purchase or qualifying ownership interest, require the tax adviser to document:

• The purchaser and tax owner.
• The acquisition and binding-contract facts.
• Evidence of when the property was placed in service.
• Eligibility and business-use analysis.
• Treatment of personal, entertainment and mixed-purpose use.
• Relevant elections, state treatment and potential consequences on disposal or changed use.

These are review questions, not an assertion that every aircraft or fractional purchase qualifies. IRS’s depreciation publication contains the wider eligibility and listed-property framework that must be considered alongside the new guidance. (irs.gov)

Recommended CFO control: maintain two models. The first compares pre-tax mission capability, contractual access and cash commitments. The second overlays the adviser-approved tax treatment. Do not allow an assumed deduction to conceal capital exposure, recurring charges, financing costs or uncertain exit proceeds.