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STRATOSIQ|Intelligence / tax-and-structuring / 100-percent-bonus-depreciation-revival-obbba-macrs
StratosIQ Intelligence • tax and structuring

100% Bonus Depreciation Revival (OBBBA) & MACRS Pooling in 2026 Corporate Aviation

    Executive Summary

    Signed into law on July 4, 2025, the One Big Beautiful Bill Act (OBBBA) permanently restored 100% bonus depreciation for qualifying aircraft placed in service on or after January 20, 2025. Aircraft acquisitions in 2026 remain eligible for full immediate cost expensing, provided strict business use parameters are maintained.

    Key Compliance Metrics

  1. IRC Section 280F QBU Test: Qualified Business Use must exceed 50% of total flight hours.
  2. Depreciation Recapture Mitigation: Structural flight logs prevent forced ordinary income recognition upon audit.
  3. Optimization Strategy

    Aircraft owners structuring for the OBBBA-restored 100% bonus depreciation should prioritize contemporaneous flight logs that cleanly separate qualified business use from personal use on a per-flight basis, not a monthly estimate — IRC Section 280F's 50% QBU threshold is tested and can be challenged at the individual-flight level on audit. Where usage sits close to the 50% line, consider whether a Part 91 dry-lease structure or adjusted ownership allocation better protects the depreciation position before the aircraft is placed in service, since the QBU percentage is materially harder to correct retroactively than to structure correctly upfront.

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