Reimbursements Under Part 91: Myth versus Reality

Rotor Safety Challenge (RSC)
Tracks: Operations, Rotor Business
Instructor: Todd Dixon and Mary Comazzi, Barnes & Thornburg LLP

Aircraft dry leasing and the various commercial exemptions found in the US Code of Federal Regulations can be very beneficial operating tools, but a lack of understanding (or even intentional disregard) of proper structuring is resulting in a major crackdown by the FAA and the IRS on alleged “illegal charter” operations and “sham” dry leases. This session will outline the necessary elements for dry leasing, time-sharing, interchange agreements, and demonstration flights. We will also examine past and current enforcement litigation on alleged intentional or inadvertent violations of regulatory exceptions and discuss the range of resulting sanctions.

Instructor Bio

Mary Comazzi, of counsel at Barnes & Thornburg LLP, has experience structuring aviation transactions, including domestic and foreign-based aircraft purchases and sales, aircraft leasing agreements, time-share and interchange agreements, joint and fractional ownership agreements, personal and executive use policies, FAA registrations, and Cape Town Convention and International Registry matters. While in-house with CHI Aviation, she developed, implemented, and managed programs involving all aspects of its business, including import–export regulatory compliance, Department of Transportation and FAA compliance, and facility and employee security clearances.

Todd Dixon is a partner at Barnes & Thornburg LLP, where he focuses on aviation law. A retired military officer and pilot, Todd is passionate about this area of law and the clients he serves. His work encompasses a wide variety of airline, airplane, and aviation-related issues involving ownership, operational structure, contractual disputes, and regulatory compliance. He has structured aviation transactions, including domestic and foreign-based aircraft purchases and sales, like-kind exchanges, time-share agreements, interchange agreements, joint and fractional ownership agreements, personal and executive use policies, FAA registrations, Cape Town Convention and International Registry matters, and aircraft leasing transactions.