Under the Act, the difference between the actual cost of personal entertainment flights provided for “specified individuals” and the amount included as income for the individual (based on SIFL or Fair Market Valuation), is disallowed as a deduction to the corporation.

“IRS did make changes dealing with the treatment of depreciation and interest expenses. The final rules provide that, in the case of a taxpayer making the election to use the straight line depreciation method for purposes of the disallowance calculation, the disallowed depreciation in any year will not exceed the allowable depreciation for such year. Also, interest is now included in the costs subject to disallowance if the underlying debt is secured by or allocable to an aircraft used to provide entertainment flights.”

NBAA Personal Use of Business Aircraft Handbook