On Nov 21, 9:00 pm, Ron Garret wrote:
Exactly. The problem here is the precise meaning of the word
"compensation" and whether or not compensation is distinct from
"reimbursement."

Can you explain why you think that matters here? If your travel
reimbursement is "compensation or hire", then you're fine because
61.113(b) permits a private pilot to fly for compensation or hire in
that situation. Alternatively, if (implausibly) the reimbursement is
*not* "compensation or hire", then you're still fine because in that
case, there is no violation of 61.113(a).

There are two ways to look at the situation. One is
that I paid the entire cost of the flight and was reimbursed for a
travel expense.

Yup, or compensated. Makes no difference.

The second is that the company paid the entire cost of
the trip and therefore I did not meet the "pro-rata share" requirement.

The pro rata requirement is irrelevant here. It's in a different
clause (61.113(c)) and spells out a different exception to the no-
compensation rule.

It's true that there's a slight ambiguity in the form of the clauses
(though it has nothing to do with "compensation" vs. "reimbursement").
As written, it might seem that 61.113(c) could apply simultaneously
with 61.113(b), forcing you to pay a pro rata share of the business
flight. But common sense easily resolves that ambiguity. The FAA can't
intend both clauses to apply to a business flight, because if they
did, then your pro rata share if there were *no* passengers would
be100%. Therefore, you'd be allowed to receive compensation *only if
you carried passengers*, which is exactly the opposite of the
constraint that the FAA is trying to impose (they don't want private
pilots to carry passengers for compensation; 61.113(b)(2) says so).

So there's really no ambiguity. Compensation is permitted in that
situation (unless you're being paid *extra* to take passengers along;
that would violate 61.113(b)(2)).