In a recent memorandum, the FAA scrutinized two complex aircraft lease arrangements involving multiple corporate entities to find that the corporations engaged in wet leasing without the requisite Part 119 certificates.  Although the situations analyzed in the memorandum were hypothetical, they reflect real-world issues that arise when subsidiaries or shell entities are formed for the sole purpose of leasing aircraft within the company or to closely related entities.  Corporations seeking to own or lease aircraft should consult with an aviation attorney experienced in ownership and leasing issues.