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IRS.gov Website
Publication 510
taxmap/pubs/p510-009.htm#en_us_publink1000274674

Surtax on any liquid used in a fractional ownership program aircraft as fuel(p11)

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Fuel used in a fractional ownership program aircraft (as defined below) after March 31, 2012, is subject to a surtax of $.141 per gallon. The fractional ownership program manager is liable for the tax. The surtax applies in addition to any other taxes imposed on the removal, entry, use, or sale of the fuel. If the surtax is imposed, the following air transportation taxes do not apply.
These taxes are described under Air Transportation Taxes, later.
A fractional ownership program aircraft flight is considered noncommercial aviation, for the rules for kerosene used in noncommercial aviation, see Kerosene for Use in Aviation above.
taxmap/pubs/p510-009.htm#en_us_publink1000274675

Fractional ownership aircraft program(p11)

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is a program under which:
taxmap/pubs/p510-009.htm#en_us_publink1000274678

Fractional program aircraft.(p11)

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Any aircraft that, in any fractional ownership aircraft program, is listed as a fractional program aircraft in the management specifications issued to the manager of such program by Federal Aviation Administration under subpart K of part 91 title 14, Code of Federal Regulations, and is registered in the U.S.
Fractional program aircraft are not considered used for transportation of a qualified fractional owner, or on account of such qualified fractional owner when they are used for flight demonstration, maintenance or crew training. In such situations, the flight is not commercial aviation. Instead, the tax on the fuel used in the flight is imposed at the non-commercial aviation rate.
taxmap/pubs/p510-009.htm#en_us_publink1000284773

Fractional owner.(p11)

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Any person owning any interest (including the entire interest) in a fractional program aircraft.
taxmap/pubs/p510-009.htm#en_us_publink1000274679

Dry lease aircraft exchange.(p11)

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An agreement, documented by the written program agreements, under which the fractional program aircraft are available, on an as-needed basis without crew, to each fractional owner.
taxmap/pubs/p510-009.htm#en_us_publink1000284774

Special rule relating to deadhead service.(p11)

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A fractional program aircraft will not be considered to be used on account of a qualified fractional owner when it is used in deadhead service and a person other than a qualified fractional owner is separately charged for such service.
taxmap/pubs/p510-009.htm#en_us_publink1000284775

More information.(p11)

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See section 4043 for more information on the surtax.