What are the tax differences between owning a fractional interest and owning a 100% interest?
Very few. In general, the benefits and burdens from a tax point of view are exactly the same for ownership of a whole or fractional interest in and aircraft. There may be slight differences in Federal Excise Tax (“FET”) for “taxable transportation by air” provided to affiliates on a wholly owned aircraft, if they are not members of the same “affiliated group.” Most fractional programs charge FET on the hourly fee.
