Do airline crew treaty rules apply to private charter flying?
Often they do not, and that is the central point for this kind of flying. The crew article in most treaties applies to aircraft operated in international traffic, and corporate and charter work frequently is not that: the aircraft is not operated in scheduled international traffic, so the article does not reach the income. When it does not apply, the income falls back to the ordinary employment rules, which allocate by reference to where the duties were actually performed. That makes the day count decisive for exactly the pilots who are most often told it does not matter.
How should I count my days flying into the United States?
Day by day, from records made at the time. Once the crew article does not apply, the ordinary employment rules allocate the income by where the duties were performed, so the count is not an administrative detail, it is the calculation. Build it from flight logs, duty records and the operator's scheduling system rather than from recollection, and record arrivals and departures rather than sectors flown. Keep the source against each day. A pilot who flies into a country constantly is not necessarily taxable there, but cannot demonstrate either answer without the record.
My operator says the crew article covers me — is that right?
It may not be, and the operator is not the party who has to defend it. The question is whether the aircraft you fly is operated in international traffic in the sense the treaty uses, not whether the employer describes itself as an airline. Private charter and corporate flights commonly fall outside that description, which pushes the income back to the ordinary employment rules and the day count. Ask what the assertion rests on. If the answer is that this is how the operator has always treated its crew, treat it as an assumption and test it against the wording.
I am paid by a management company abroad — who taxes my salary?
Start with what the arrangement actually is rather than with what the paperwork says, because the two diverge often in this part of the industry. Identify who directs the flying, whose aircraft is flown, where the duties are performed and which entity bears the cost. Then read the treaty between the countries that fact pattern really involves. Where the crew article does not apply, the ordinary employment rules follow the duties, and the payer's location is not by itself the answer. Paperwork that does not match reality is an exposure in its own right and is worth correcting before a question arrives.
What records do I need to prove where I worked each day?
Enough to reconstruct the year without relying on memory: flight logs, duty and rest records, the operator's schedule, and passport or boarding evidence for entries and exits. Keep them monthly rather than assembling them under pressure after the year has closed. Because the ordinary employment rules allocate by where the duties were performed, the record is what supports the allocation, and a day you cannot evidence is a day the other side gets to characterise. Reproduce the year from a travel record rather than from recollection, because that record is the first thing anybody asks for.
Why is my tax position different from the airline pilots I fly with?
Because the treaty article that governs them may not govern you. Airline crew on aircraft in scheduled international traffic usually fall within a dedicated article that allocates their employment income by reference to the employer or to the enterprise's management. Corporate and charter flying often sits outside that article, so the same roster pattern produces a different answer: the ordinary employment rules apply, and the days worked in each country matter. Pilots sharing a cockpit can be in genuinely different positions, and what separates them is the nature of the operation rather than the aircraft type.
Is GILTI computed at the CFC level or the shareholder level?
Both, in sequence. Tested income, tested loss and the qualifying asset base are measured company by company. They are then aggregated at the US shareholder, which is where the netting of losses across companies happens and where the inclusion, the deduction and the credit are determined. That order matters in practice: a loss in one foreign subsidiary can reduce the inclusion caused by another, but only for a shareholder who owns both. See the GILTI inclusion and Form 8992.
Which country do I pay tax to first?
Generally the source country — where the income arises — taxes first, often by withholding before you receive it. Your country of residence then taxes the same income and credits what the source country took. That order is why timing matters: a residence-country return filed before the source-country tax is settled has nothing to credit yet. Getting the sequence right is most of the work. See international tax planning.
