The One Big Beautiful Bill Act (OBBBA) reinstated and made permanent 100% bonus depreciation for eligible property¹ acquired and placed into service after January 19, 2025, including aircraft. This means the full cost of a qualified aircraft could potentially be deducted² from the purchaser’s taxable income in the year the aircraft is placed into service.
The tax ramifications around owning an aircraft are complex and we recommend you consult with a tax advisor.³
Buyers financing an aircraft or refinancing existing aircraft loans may use the aircraft purchased as collateral. This solution may reduce the need to liquidate other assets or disrupt your investment portfolio.
For example, consider a New York-based client and entrepreneur who has decided to purchase an aircraft for business use following a recent liquidity event. He was able to partner with his advisor and Goldman Sachs Private Bank to find a structured financing solution that did not disrupt an existing liquidity management plan. The Private Bank evaluated the individual's liquidity, leverage, and cash flow, as well as the subject aircraft's specification sheet, appraisal, age, condition, and usage. The entrepreneur was able to obtain a $10.5 million loan secured by the aircraft.
While bonus depreciation under OBBBA doesn’t apply to aircraft primarily intended for personal use, strategic financing strategies may be available for such purchases.
One option is structured lending solutions, which use eligible securities in an investment portfolio or other assets such as alternative investments and real estate, for a line of credit. Clients can finance an aircraft purchase using a structured loan, avoiding possible asset liquidation and associated tax consequences, all while maintaining their current investment strategy.
Alternatively, if you choose to purchase an aircraft intended for personal use with cash, you may decide to take out a loan against the aircraft and use the proceeds to invest in taxable securities. Since interest paid on money borrowed for taxable investing is generally deductible in the US as investment interest expense, the cost of borrowing may be less than expected because of tax savings realized by lowering taxable income. This financing option could help provide liquidity, while maintaining your current investment strategy.
The table below outlines an example of aviation financing eligibility for both business and personal use.
Minimum loan amount |
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Types |
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Collateral |
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Key Uses |
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1 Defined in Internal Revenue Code section 168(k).
2 The deduction could potentially be limited. A list of potential limitations includes but is not limited to: Business vs. Personal usage of aircraft, Passive Activity Loss Rules (§469), Excess Business Loss Limitations (§461(l)), and Interest Deduction Limitations (§163(j)).
3 Goldman Sachs does not provide accounting, tax or legal advice and you are strongly encouraged to consult your own advisors before implementing any structure or strategy discussed in this publication.
This material is not an offer or commitment to provide a loan or other financing. All finance is subject to underwriting and credit approval. Additional terms and conditions apply and may change at any time. This material is intended for educational purposes only and is provided solely on the basis that it will not constitute investment advice and will not form a primary basis for any personal or plan’s investment decisions. While it is based on information believed to be reliable, no warranty is given as to its accuracy or completeness, and it should not be relied upon as such. Goldman Sachs is not a fiduciary with respect to any person or plan by reason of providing the material herein, information and opinions expressed by individuals other than Goldman Sachs employees do not necessarily reflect the view of Goldman Sachs. This material is not an offer or solicitation with respect to the purchase or sale of any security in any jurisdiction in which such offer or solicitation is not authorized or to any person to whom it would be unlawful to make such offer or solicitation. Investing involves risk, including the potential loss of money invested. Past performance does not guarantee future results. Neither asset diversification or investment in a continuous or periodic investment plan guarantees a profit or protects against a loss. Information and opinions provided herein are as of the date of this material only and are subject to change without notice.
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Securities-Based Lending Important Information Loans collateralized by securities may not be appropriate for all parties and carry a number of risks, including the risk of a market downturn, tax implications if pledged securities are liquidated, and the potential fluctuation in interest rates. If the value of pledged securities declines below certain levels, the client (with assistance from their advisor) may be required to pledge additional collateral, rebalance existing collateral through trading, or pay down the loan to avoid the forced sale of securities to meet collateral maintenance requirements. Subject to applicable law, pledged securities may be sold with or without advance notice to the client to cover the deficiency at the bank’s sole discretion. Clients should understand the possible adverse tax consequences associated with the sale or pledge of their securities when considering whether a securities-based loan is appropriate for them.
Collateral-Based Lending Important Information Loans collateralized by a direct or indirect interest in real property or personal property may not be appropriate for all parties and can carry a number of risks, including the risk of loss of some, all, or substantially all value of the pledged collateral. If the marketable value of the underlying pledged asset falls below a certain level, the Borrower may be required to pledge additional collateral or pay down part of the loan prematurely. Client should understand the possible potential adverse tax consequences when considering whether a collateral based loan is appropriate for them.
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