Congress doesn’t want investors trading stock‑like assets for partnership units and escaping tax. So if, after your contribution, more than 80 % of the Pod’s assets are cash, or marketable securities the IRS treats the deal as a taxable sale.
Craft avoids that outcome with two simple habits:
Plane first, cash later. We always book an aircraft (or other non‑security asset) before accepting large cash or securities, keeping the “bad‑asset” tally well under 80%.
Watch the mix. We keep an eye on the balance sheet so any cash raised for upgrades or reserves is quickly deployed into aircraft costs, holding the good‑asset percentage high.
Because an aircraft anchors the balance sheet and cash never tips us over the 80% line, the Pod stays safely outside the § 721(b) investment‑company trap.