
BROUGHT TO YOU BY FLYING FINANCE
Every tax season, FLYING Finance sees a version of this question trend in searches and our inbox: “Can I write off financing for a type rating (or an instrument rating, or recurrent training)?” It’s a fair question, and an expensive one to get wrong.
Flight training isn’t cheap, and the difference between a fully deductible business expense and a personal expense you’re paying for with after-tax dollars can run into thousands of dollars a year.
The boring answer is that it depends and that you should talk to a CPA or tax attorney familiar with aviation, but we can get you started with the basics. The IRS actually draws a fairly specific line here. Once you understand the parameters, you can plan your training around it instead of guessing.
Two-Part Test
The core rule comes from IRC Section 1.162-5, and it boils down to two factors. Your training expense may be deductible if it either maintains or improves skills required in your current job, trade, or business, or if your employer (or the law) requires the training to keep your current salary, status, or position.
That sounds straightforward until you hit the second half of the regulation, which is where some pilots get tripped up. Even if your training clears that first bar, it’s still not deductible if it’s part of a program that qualifies you for a new trade or business, or if it satisfies the minimum educational requirements to enter your current one.
That second clause knocks out the idea some aspiring pilots have of getting a private pilot certificate so you can eventually use the airplane for work. It doesn’t matter how business-minded your intentions are. If the certificate itself qualifies you for something new, the IRS treats it as personal education, full stop.
A few real scenarios make this concrete, and the Tax Court has ruled on more of these than you would expect.
Instrument rating: This is probably the most common real-world case. Imagine a business owner who already flies for company travel and wants to add an instrument rating to fly more reliably in weather. Because it’s improving a skill within a certificate you already hold and use for business, this might seem like it would be deductible more than a brand-new certificate would. It’s one of the more scrutinized areas, though, so documentation matters as much as the training itself.
Type ratings: In one of the more instructive Tax Court cases, a corporate pilot flying turboprops for his employer paid out of pocket for a jet type-rating course. His employer didn’t own that aircraft and never reimbursed him. The IRS disallowed the deduction, but the Tax Court sided with the pilot. The training maintained and improved skills relevant to his existing profession as a pilot, even though his employer’s fleet didn’t include that airplane.
Training for a rating your employer doesn’t require and won’t use: In a different case, a pilot pursued helicopter training while employed as a fixed-wing pilot. Neither the FAA nor his employer required it, and the court found he was trying to qualify himself for a new kind of flying rather than improve his existing job performance. That one didn’t win out.
Employer-required training: This is the cleanest case in the tax code. If your employer mandates a rating, recurrent training, or a specific course as a condition of keeping your job, salary, or status, that expense is about as safe a deduction as exists in aviation. The ambiguity that surrounds “improving skills” mostly disappears when there’s a written requirement behind it.
W-2 Complications
In recent years, there has been another significant change for W-2 employees. Airline, corporate, or government W-2 pilots generally can’t deduct unreimbursed training costs at all anymore, regardless of how clearly it maintains or improves skills.
The Tax Cuts and Jobs Act (TCJA) suspended the deduction for unreimbursed employee business expenses starting in 2018, and legislation passed in 2025 made that suspension permanent for most workers.
In practice, that means a W-2 airline captain who pays out of pocket for a type rating their employer doesn’t reimburse is out of luck at the federal level, even though the same training would have been deductible before 2018, despite the fact that the underlying skills-based test hasn’t changed.
Where this really matters for most FLYING Finance clients is the owner-operator and independent contractor world. If you fly Part 91 for your own business, or you’re a 1099 contract pilot, instructor, or charter pilot, none of this applies to you the same way. You still file a Schedule C and can deduct legitimate, ordinary, and necessary training expenses tied to your business. The TCJA change targeted W-2 employees specifically, not self-employed pilots.
Documentation for Audit
None of this matters if you can’t back it up. The IRS and the Tax Court cases mentioned lean heavily on paper trails. A few things are worth doing before you ever sit down with a CPA:
- Keep a written record of why the training was necessary for your current role.
- If your employer requires the training, get that in writing.
- Separate training logged for a business purpose from training logged for personal enjoyment or a future career change.
- If you’re a Schedule C filer, track the training expense the same way as any other ordinary and necessary business cost, tied specifically to the aircraft or operation.
What’s Not Deductible, No Matter What
A couple of categories are worth stating plainly, because some people still try to find an angle around them. Initial pilot certificates are considered the minimum qualification for a new trade or business, which makes them non-deductible even when your ultimate goal is business use of the aircraft.
Training aimed at a career change carries the same problem. If the purpose or effect of the training is to qualify you for work you don’t currently do, the IRS doesn’t care how directly it might benefit a future employer or business. That’s the “new trade or business” test. No amount of creative documentation gets around it.
If you’re not sure which category you fall into, or how a lender will view training costs versus an aircraft loan, that’s exactly the kind of question worth working through with us at FLYING Finance before you sign anything.
