SecProbe.io

Mail Stop 3561
May 19, 2016

Derek J. Kerr
Chief Financial Officer
4333 Amon Carter Boulevard
Fort Worth, Texas 76155

Re: American Airlines Group Inc.
 Form 10-K for the Year Ended December 31, 2015
Filed February 24, 2016
File No. 001 -08400

Dear Mr. Kerr :

We have limited our review  of your filing  to the financial statements and related
disclosures and have the following comments.  In some of our comments, we may ask you to
provide  us with information so we may better understand your disclosure.

Please respond to these comments  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.

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

Form 10 -K for the Year Ended December 31, 2015

Financial Statements

Notes to Co nsolidated Financial Statements of American Airlines Group Inc.

10.  Income Taxes, page 137

1. Based upon your disclosures on page 9 and 23 , we note you derive approximately 30% of
your total operating revenues in 2015 from foreign operations.  Please be ad vised that
Rule 4 -08(h) of Regulation S -X requires the components of income (loss) before income
tax expense and income tax expense be disclosed as either domestic or foreign in the
income  statement or notes to the consolidated financial statements.  Pleas e revise to
comply or advise us of why  you are not required to do so.

2. We note from your disclosure on page 138 that after considering all positive and negative
evidence , including the completion of certain critical merger integration milestones as

Derek J. Kerr
American Airlines Group Inc.
May 19, 2016
Page 2

 well as your financial performance, you concluded that substantially all of your deferred
income tax assets were more likely than not to be realized.  This resulted in a $3 billion
non-cash tax benefit recorded in your income statement for 2015.  Given the sig nificance
of the reversal, please tell us and revise the critical accounting policy related to income
taxes in MD&A to discuss in greater detail the nature of the positive and negative
evidence considered by management in determining the likelihood the def erred tax asset
will be realized in these circumstances.  The enhanced disclosure should provide
sufficient information to enable a reader to evaluate the quality of the deferred tax asset.
Such information may include use of tax planning strategies, expe ctations for future
income, etc.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchan ge Act rules require.   Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

 In responding to our comments, please p rovide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

You may contact Heather Clark at 202 -551-3624 or Jean Yu  at 202 -551-3305 if you have
questions regarding comments on the financial statements and related matters.  P lease contact me
at 202 -551-3377  with any other questions.

Sincerely,

 /s/ Andrew Mew

Andrew Mew
Senior Assistant Chief Accountant
Office of Transportation and Leisure