November 5, 2024

Eun (Angela) Nam
Chief Financial Officer and Chief Accounting Officer
FTAI Aviation Ltd.
415 West 13th Street, 7th Floor
New York, NY 10014

       Re: FTAI Aviation Ltd.
           Form 10-K for Fiscal Year Ended December 31, 2023
           Item 2.02 Form 8-K filed July 24, 2024
           File No. 001-37386
Dear Eun (Angela) Nam:

       We have reviewed your filings and have the following comment(s).

       Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.

Form 10-K for Fiscal Year Ended December 31, 2023
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations, page 32

1.     Please substantially revise both your consolidated and segment results
of operations
       discussions to disclose in greater detail the underlying business
reasons for material
       changes between periods in each line item. In circumstances where there
are more
       than one underlying business reason for the change, quantify the
incremental impact
       of each individual reason discussed on the overall change in the line
item. Refer to
       Item 303 of Regulation S-K.
Consolidated Balance Sheets, page 53

2.     Please disclose total current assets and total current liabilities for
all periods
       presented. Refer to Rules 5-02.9 and .21 of Regulation S-X.
 November 5, 2024
Page 2

Consolidated Statements of Operations, page 54

3.     Please present cost of tangible goods sold, expenses applicable to
rental income, cost
       of services and expenses applicable to other revenues separately. Refer
to Rule 5-03.2
       of Regulation S-X.
4.     Please include gain on sale of assets, net in the same area of the
statements of
       operations as your operating items. Also, include interest expense in
the same area of
       the statements of operations as your non-operating items. Refer to Rules
5-03.3
       through .9 of Regulation S-X and ASC 360-10-45-5.
Consolidated Statements of Cash Flows, page 58

5.     Please disclose in greater detail the nature of each non-cash activity
shown in the
       supplemental disclosures. The revised disclosures should clearly discuss
both sides of
       the non-cash transactions, so that it is transparent why the
transactions are non-cash.
       For the transfers from leasing equipment, please also disclose the asset
category to
       which the transfers were made and the circumstances surrounding the
transfers. Also,
       tell us whether these assets were still under lease at the time of
transfer and quantify
       the amounts for each period presented. Next, tell us and disclose
whether the later
       cash inflows from the sale/disposition of leasing equipment transferred
to inventory
       are included in investing activities or operating activities. If these
later cash inflows
       are not included in investing activities, explain in detail how your
inconsistent
       classification for the cash outflows and cash inflows complies with
GAAP. For all
       cash inflows included in operating activities related to leasing
equipment transferred
       to inventory, tell us the amounts for each period presented, including
2024 interim
       periods. If there have been transfers from inventory to leasing
equipment or other
       long-lived assets, provide revised disclosures presenting this non-cash
activity
       separately and include a similar GAAP analysis with quantification of
cash
       inflows included in investing activities related the sale/disposition of
inventory
       transferred to leasing equipment or other long-lived assets. Finally,
disclose in a
       footnote your accounting policy for cash inflows and cash outflows
related to each
       category of transferred assets (before transfer and after transfer).
Refer to ASCs 230-
       10-45-22 and 45-22A.
Note 11. Income Taxes, page 76

6.     Please disclose for each period presented the amounts of domestic and
foreign pre-tax
       income. Refer to Rule 4-08(h)(1) of Regulation S-X.
Note 13. Segment Information, page 80

7.     Please disclose the amounts of revenues and long-lived assets for each
individual
       country that is material. Refer to ASC 280-10-50-41.
 November 5, 2024
Page 3

Item 2.02 Form 8-K filed July 24, 2024
Exhibit 99.1
Business Highlights, page 1

8.     Please present net income (loss) attributable to shareholders for your
aerospace
       products segment, when adjusted EBITDA for your aerospace products
segment is
       presented. Also, provide a reconciliation between the amounts.
        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence
of action by the staff.

       Please contact Blaise Rhodes at 202-551-3774 or Rufus Decker at
202-551-3769 if
you have any questions.



                                                         Sincerely,

                                                         Division of
Corporation Finance
                                                         Office of Trade &
Services