Under a September 25, 1991 ruling by the Comptroller General of the U. S.
[70 Comp. Gen. 713 B-240956, 1991 WL211352 (C.G.) entitled "Fly America
Act--Code Sharing--Transportation by U.S. Carrier," it was determined
that "shared space" agreements between U.S. and foreign air carriers
constituted the leasing of space on the foreign carrier by the U.S.
carrier and therefore  such space is under the control of the lessor even
though non-U.S. equipment is being used.

Since code sharing agreements benefit the U.S. carrier financially, they
operate in the spirit of the Act.

Operationally,  as long as the ticket is issued on the U.S. carrier
ticket stock and carries the U.S. carrier's flight coding, it IS an
allowable expense on federally sponsored programs.

Donald M. Wood, Ph.D.
Office of Contracts & Grants
440 W. Franklin St., CB# 1350
UNC Chapel Hill, NC 27599-1350
Ph.:919-962-4672/966-3411
FAX: 919-962-5011
eMAIL: xxxxxx@UNC.EDU