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IRS Expands 100 Percent Bonus Depreciation for Business Aircraft

IRS Notice 2026-11 clarifies 100% bonus depreciation eligibility for business aircraft delivered after January 19, 2025, benefiting accrual-basis taxpayers.

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This article summarizes reporting by the National Business Aviation Association (NBAA).

IRS Guidance Expands 100% Bonus Depreciation Eligibility for Aircraft Owners

On January 14, 2026, the Internal Revenue Service (IRS) issued Notice 2026-11, providing critical interim guidance regarding the “One Big Beautiful Bill Act” (OBBBA). This legislation, signed into law in July 2025, permanently reinstated 100% bonus depreciation for qualified property, including business aircraft, acquired and placed in service after January 19, 2025.

According to an industry update published by the National Business Aviation Association (NBAA), the new guidance offers a significant technical clarification that could save aircraft buyers millions in tax liability. Specifically, the guidance addresses the treatment of “binding written contracts,” potentially allowing taxpayers who ordered aircraft under previous, less favorable tax rules to qualify for the full 100% deduction upon delivery.

The “Binding Contract” Trap and the New Solution

Under the Tax Cuts and Jobs Act (TCJA) of 2017, bonus depreciation was scheduled to phase down. For the 2025 tax year, the deduction was set to drop to 40% generally, or 60% for certain aircraft with longer production periods. Many buyers signed binding purchase contracts in 2024 or early 2025 expecting these lower rates.

Typically, tax rules consider property “acquired” on the date a binding written contract is signed. This created a potential trap: buyers who signed contracts before the new law took effect (on or before January 19, 2025) but took delivery afterward might have been locked into the lower phase-down rates.

Relief for Accrual-Basis Taxpayers

The NBAA reports that Notice 2026-11 provides a vital workaround. The guidance clarifies that for accrual-basis taxpayers, a category that includes most corporations and large flight departments, the acquisition can effectively be treated as occurring upon delivery or title transfer.

Consequently, a buyer with a contract from 2024 who took delivery on January 25, 2025, may now claim 100% depreciation rather than the previously expected 40% or 60%. However, the NBAA notes that cash-basis taxpayers face a more difficult hurdle, as they recognize expenses when cash is paid, potentially leaving them subject to older rates if significant payments were made prior to the cutoff.

“Business aircraft owners require a detailed factual analysis in order to present accurate tax returns. There are advanced technical positions that support eligibility for 100% bonus depreciation…”

, David Shannon, Partner at Lewis Brisbois (via NBAA)

Strategic Elections: When to Take Less

While the return of 100% bonus depreciation is generally welcomed, the IRS guidance also outlines a “Transition Election” allowing taxpayers to opt for the lower rates. According to the research data, taxpayers can choose to apply the 40% rate (or 60% for longer-production aircraft) for the first tax year ending after January 19, 2025.

Tax experts suggest this counterintuitive move may be vital for specific tax planning strategies:

  • Preserving Net Operating Losses (NOLs): A full 100% write-off might generate a loss larger than the company can utilize, as NOLs are generally limited to 80% of taxable income.
  • Future Rate Arbitrage: If a company anticipates higher corporate tax rates in future years, deferring deductions by taking a smaller percentage now could yield greater long-term savings.
  • Credit Preservation: Reducing taxable income to zero might cause other valuable tax credits to expire unused.

AirPro News Analysis

We believe this guidance will have an immediate stabilizing effect on the pre-owned and new aircraft markets in Q1 2026. Throughout late 2025, uncertainty regarding the “binding contract” rule likely caused hesitation among buyers who were unsure if their transactions would qualify for the reinstated OBBBA benefits.

With the IRS confirming that delivery dates can supersede contract dates for accrual-basis taxpayers, we expect a flurry of retroactive tax planning for 2025 returns. Furthermore, the permanent nature of the 100% deduction removes the “use it or lose it” pressure that defined the previous phase-out era, likely leading to more consistent, sustainable demand rather than artificial year-end spikes.

Frequently Asked Questions

What is the effective date for the new 100% bonus depreciation?
The 100% rate applies to qualified property acquired and placed in service after January 19, 2025.

Does this apply to contracts signed in 2024?
Potentially. According to the new guidance, accrual-basis taxpayers who took delivery after January 19, 2025, may qualify for the 100% rate even if the contract was signed earlier. Consultation with a tax professional is required.

Can I still choose the 60% rate?
Yes. The guidance allows for a “Transition Election” to use the lower phase-down rates (40% or 60%) if that benefits your specific tax situation, such as preserving Net Operating Losses.

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Photo Credit: NBAA

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Business Aviation

Apollo and KKR Value Atlantic Aviation at Nearly $10 Billion

Apollo and KKR announced a strategic partnership valuing FBO network Atlantic Aviation at nearly $10 billion in August 2026.

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Apollo Global Management and KKR & Co. Inc. announced a strategic partnership on August 27, 2026, valuing fixed-base operator (FBO) network Atlantic Aviation at nearly $10 billion. The transaction sees Apollo-managed funds acquire a significant stake in the company, while KKR retains a substantial shareholder position.

In a joint press release, the investment firms outlined plans to support the continued expansion of Atlantic Aviation, which provides mission-critical infrastructure such as aircraft fueling and hangar leasing across the United States. The $10 billion valuation represents a sharp increase from the $4.5 billion KKR paid to acquire the company from Macquarie Infrastructure in 2021, reflecting sustained demand for private aviation facilities.

Strategic Investment and Market Positioning

Investments: Apollo has originated $155 billion in infrastructure transactions across various sectors over the past five years. KKR brings extensive sector experience, having invested $12 billion across the aviation industry since 2015 and currently managing $120 billion in infrastructure assets.

David Cohen, a partner at Apollo Global Management, highlighted the company’s irreplicable infrastructure footprint across busy Airports, which is supported by long-term concession agreements.

“The private aviation market has structural tailwinds that we believe will persist, and Atlantic is well positioned to capture that growth. We look forward to working closely with Jeff, the entire Atlantic team and KKR to build on its momentum through targeted investment and strategic new market expansion.”

Dash Lane, a partner at KKR & Co. Inc., noted that the continued support reflects conviction in the platform and the long-term growth of the sector. Lane stated that the firm has worked closely with the Atlantic Aviation team over the past five years to expand and strengthen the business.

Operational Impact for Atlantic Aviation

Atlantic Aviation CEO Jeff Foland characterized the investment as a validation of the company’s performance and potential.

“This transaction is more than a milestone for Atlantic, it is a powerful validation of what our people have built together. To have two of the world’s most respected investment firms choose to invest in our company is an extraordinary endorsement of our people, our performance, and our potential.”

The exact financial terms, including the specific purchase price paid by Apollo and the resulting ownership split between the two firms, were not disclosed in the announcement.

AirPro News analysis

We view the doubling of Atlantic Aviation’s valuation over a five-year period as a clear indicator of the premium placed on established FBO networks. The private aviation sector has experienced sustained structural growth, compounded by broader commercial aircraft shortages and an overall increase in private flight activity. Because airport real estate is finite and long-term concession agreements create high barriers to entry, incumbent FBO operators hold significant pricing power. The combined financial backing of Apollo and KKR will likely accelerate Atlantic Aviation’s acquisition of independent FBOs and expansion into new regional markets.

Sources: Apollo Global Management

Photo Credit: Atlantic Aviation

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Business Aviation

Atlantic Aviation Breaks Ground on New FBO at Nashville JWN

Atlantic Aviation begins construction of a new executive FBO terminal and hangar at John C. Tune Airport, due Q4 2027.

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Atlantic Aviation has officially commenced construction on a new executive fixed-base operator (FBO) terminal and hangar complex at John C. Tune Airports (JWN) in Nashville, Tennessee, expanding its infrastructure footprint in the region.

Announced in a press release on August 25, 2026, the project is slated for completion in the fourth quarter of 2027. The development follows Atlantic Aviation’s successful bid for a new leasehold through a Metropolitan Nashville Airport Authority (MNAA) request for proposals in May 2025 and complements the company’s existing operations at Nashville International Airport (BNA).

Facility specifications and infrastructure

The planned facility will feature a 7,500-square-foot executive terminal alongside a 37,000-square-foot hangar and office complex. To accommodate aircraft movement and parking, the project includes the development of approximately 175,000 square feet of new ramp space.

The infrastructure upgrades will incorporate a new fuel farm with a 60,000-gallon capacity for Jet-A and a 12,000-gallon capacity for 100LL aviation gasoline. According to the company, the design integrates Sustainability initiatives, including Leadership in Energy and Environmental Design (LEED) focused elements, efficient building systems, and construction waste minimization strategies.

Strategic expansion in the Nashville market

Located eight miles west of downtown Nashville, John C. Tune Airport serves as a primary reliever for BNA and a key gateway for general aviation. MNAA President and Chief Executive Officer Doug Kreulen stated that the expansion marks a major step forward in strengthening access for the area’s growing general aviation community.

“By bringing world-class facilities and services to John C. Tune Airport, Atlantic Aviation is helping us position the airport for long-term success, and we’re excited for the expanded opportunities this Investments will create for our customers and for Middle Tennessee,” Kreulen said.

Atlantic Aviation Chief Executive Officer Jeff Foland described the start of construction as an exciting milestone for the Partnerships. The company previously opened a newly completed FBO facility at BNA in June 2024.

AirPro News analysis

We view Atlantic Aviation’s dual-airport Strategy in Nashville as a direct response to the region’s sustained economic and population growth. By establishing a modern presence at JWN just two years after securing the leasehold, the company is positioning itself to capture overflow corporate traffic that might otherwise face congestion at BNA. The inclusion of substantial ramp space and high-capacity fuel storage indicates an expectation of high-volume, large-cabin business jet traffic at the reliever airport.

Sources: Atlantic Aviation

Photo Credit: Atlantic Aviation

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Business Aviation

Avcon Industries Delivers Modified King Air B200 for Mosquito Control

Avcon Industries delivered a modified Beechcraft King Air B200 to Lee County Mosquito Control District in Florida for aerial pest mitigation.

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Avcon Industries, Inc. delivered its first specially modified Beechcraft King Air B200 equipped for large-scale mosquito mitigation to the Lee County Mosquito Control District in Florida on August 25, 2026.

In a press release, the Butler National Corporation subsidiary detailed the engineering modifications designed to support rapid airborne liquid dispersal for disease and pest prevention. The delivery provides the Florida district with a twin-engine turboprop platform capable of covering larger areas than traditional ground-based methods or smaller agricultural aircraft.

Engineering and modification details

The special mission modification centers on a removable external under-fuselage pod. The system incorporates an electric pump, aerodynamic fairings, and dispersal booms to facilitate repeatable fluid application.

Avcon Industries President Marcus Abendroth stated the project highlights the company’s capacity to integrate specialized mission systems into established airframes.

“The King Air B200 provides an excellent platform for this mission, and the solution developed by our team creates an opportunity to support similar mosquito-control and airborne dispersal requirements for other operators,” Abendroth said.

Operational impact in Florida

Mosquito mitigation remains a persistent public health requirement in Florida due to the climate and the associated risk of mosquito-borne illnesses. The Lee County Mosquito Control District utilizes aviation assets to manage these risks across extensive geographical areas.

Wayne Luettich, Aircraft Maintenance Manager for the district, emphasized the importance of the new platform for local residents.

“Mosquito control has become a significant effort in Florida. We have an important mission to mitigate the impact of the mosquitoes on our residents. We look forward to operating the Avcon-modified airplane and appreciate the Avcon engineering services,” Luettich said.

AirPro News analysis

We note that adapting business aviation platforms like the King Air B200 for public health missions reflects a demand for higher payload and extended range in aerial application. While single-engine agricultural aircraft excel in localized operations, twin-engine turboprops offer the speed and capacity required for county-wide vector control, particularly in coastal regions requiring rapid response to emerging public health threats.

Sources: Avcon Industries, Inc.

Photo Credit: Avcon Industries

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