1. Home
  2. |Insights
  3. |IRS to Kickoff Audit Campaign Focused on Business Aircraft Users

IRS to Kickoff Audit Campaign Focused on Business Aircraft Users

What You Need to Know

  • Key takeaway #1

    Individual and corporate taxpayers that improperly reported personal aircraft use as business use may face increased taxable income and penalties and/or denial of deductions.

  • Key takeaway #2

    Corporate taxpayers that allocated the affiliated individual’s use of the corporate jet as business use may be denied deduction of such use.

  • Key takeaway #3

    Taxpayers may wish to preemptively audit the prior deductions and, if the target of an IRS audit, seek advice from tax professionals with specific expertise in business aviation tax and IRS audits.

Client Alert | 1 min read | 02.29.24

Last week, the IRS announced plans to begin a campaign to audit personal use of business aircraft. The audits will focus on whether large corporations, partnerships and high-and ultra-high net worth aircraft owners have properly reported their business and personal aircraft usage for tax purposes, with a particular focus on ensuring that owners are only taking deductions to which they are entitled. Given the value of an aircraft, the amount of a deduction for aircraft related expenditures on a given taxpayer’s return can be in the tens of millions of dollars, and with more than 10,000 corporate jets operating in the U.S., IRS Commissioner Daniel Werfel recognized that much is at stake with this campaign.  The audit campaign is expected to focus initially on multinational and domestic corporations and complex partnerships but is expected to expand from there.

Insights

Client Alert | 9 min read | 10.21.26

Artificial Intelligence in Life Sciences: Reliability of AI-Generated Evidence in Drug Discovery and Development

The life sciences sector is uniquely vulnerable to the inherent risks of AI-generated evidence in drug development and discovery. This client alert focuses on five core challenges: hallucinations, skewed predictions from unrepresentative training data, the opacity of AI reasoning, input sensitivity that undermines reproducibility, and adversarial manipulation of training data. To address these risks, companies should use experimental validation and human oversight as the common legal and regulatory safety net. This entails among other measures auditing AI outputs, characterizing training data, and structural oversight. Companies also should prepare for evolving frameworks and guidance from the U.S. Food and Drug Administration (FDA) and the European Union (EU) that address use of AI in drug discovery and development .  ...