IRS agents are increasing scrutiny of the personal use of corporate jets, partly because abusive deductions can indicate that companies are taking larger upfront write-offs than they’re entitled to.

In a February 2024 Bloomberg Law article, Pillsbury partner Michael Kosnitzky said the IRS will likely start its audits with recently purchased jets and family offices, while steering away from public companies, which generally maintain “pristine records” due to disclosure obligations and access to sophisticated tax advisers.

By October 2024, Kosnitzky told Bloomberg Law that IRS agents had become “more aggressive” than in the past and “very unforgiving in terms of documentation.” The October article also noted that the IRS announced a campaign to audit corporate jet use as part of a broader initiative to collect taxes owed by wealthy individuals and complex partnerships, and that Democrats have called for tighter limits on how corporate jet owners can deduct certain travel costs.

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