FAA Matters

FAA Matters

Aircraft Registration

Aircraft registration and FAA matters involving title and liens, certification, enforcement, and drones.

Aircraft registration involves complex legal, regulatory, and jurisdictional considerations. Our aviation attorneys assist aircraft owners, purchasers, sellers, lenders, and other stakeholders with U.S. FAA registration, non-U.S. citizen registration structures, foreign jurisdiction transfers, and interests recorded on the International Registry. We provide practical guidance through the registration process, helping clients navigate ownership requirements, filing obligations, re-registration, and related compliance matters to establish and protect their interests throughout the aircraft’s ownership and transaction lifecycle.

Runway at sunset
U.S. Aircraft Registration
with the FAA

Registration of aircraft with the U.S. Federal Aviation Administration involves various legal and regulatory considerations, including ownership structure, intended use, and filing requirements. U.S.-registered aircraft must also be re-registered every 36 months, with notice provided to the registrant six months in advance. Failure to maintain registration can result in consequences such as grounding or defaults under lease and lending arrangements. We assist clients in navigating these requirements and maintaining compliant aircraft registration.

Non-U.S. Citizen Aircraft Registration with the FAA

Non-U.S. citizens may register an aircraft in the U.S. through three primary structures. FAR §47.9 allows a non-U.S. corporation to obtain N-number registration when at least 60% of the aircraft’s flight hours are accumulated in the U.S., subject to semiannual FAA reporting. FAR §47.8 permits registration through a voting trust, requiring a U.S. corporation and specific U.S. citizenship and voting-interest requirements. FAR §47.11 provides for an owner trust, where a trustee holds legal title for a foreign trustor. The appropriate structure depends on the aircraft, ownership, operation, and tax circumstances, and we assist clients in selecting and establishing the most suitable arrangement.

Registration in Foreign
Jurisdictions and Countries

In many circumstances, aircraft will change registration during the course of a purchase or sale transaction. We provide guidance in the de-registration of an aircraft from its current registration and coordination with foreign jurisdictions. Transition of registration has included but is not limited to the following registries: Isle of Man, Venezuela, Mexico, Colombia, Cayman Islands, Canada, Bahamas.

Registration of Interests
on the International Registry

In many circumstances, aircraft will change registration during the course of a purchase or sale transaction. We provide guidance in the de-registration of an aircraft from its current registration and coordination with foreign jurisdictions. Transition of registration has included but is not limited to the following registries: Isle of Man, Venezuela, Mexico, Colombia, Cayman Islands, Canada, Bahamas.

U.S. Aircraft Registration
with the FAA
U.S. Aircraft Registration
with the FAA

Registration of aircraft with the U.S. Federal Aviation Administration involves various legal and regulatory considerations, including ownership structure, intended use, and filing requirements. U.S.-registered aircraft must also be re-registered every 36 months, with notice provided to the registrant six months in advance. Failure to maintain registration can result in consequences such as grounding or defaults under lease and lending arrangements. We assist clients in navigating these requirements and maintaining compliant aircraft registration.

Non-U.S. Citizen Aircraft
Registration with the FAA
Non-U.S. Citizen Aircraft
Registration with the FAA

Non-U.S. citizens may register an aircraft in the U.S. through three primary structures. FAR §47.9 allows a non-U.S. corporation to obtain N-number registration when at least 60% of the aircraft’s flight hours are accumulated in the U.S., subject to semiannual FAA reporting. FAR §47.8 permits registration through a voting trust, requiring a U.S. corporation and specific U.S. citizenship and voting-interest requirements. FAR §47.11 provides for an owner trust, where a trustee holds legal title for a foreign trustor. The appropriate structure depends on the aircraft, ownership, operation, and tax circumstances, and we assist clients in selecting and establishing the most suitable arrangement.

Registration in Foreign
Jurisdictions and Countries
Registration in Foreign
Jurisdictions and Countries

In many circumstances, aircraft will change registration during the course of a purchase or sale transaction. We provide guidance in the de-registration of an aircraft from its current registration and coordination with foreign jurisdictions. Transition of registration has included but is not limited to the following registries: Isle of Man, Venezuela, Mexico, Colombia, Cayman Islands, Canada, Bahamas.

Registration of Interests
on the International Registry
Registration of Interests
on the International Registry

In many circumstances, aircraft will change registration during the course of a purchase or sale transaction. We provide guidance in the de-registration of an aircraft from its current registration and coordination with foreign jurisdictions. Transition of registration has included but is not limited to the following registries: Isle of Man, Venezuela, Mexico, Colombia, Cayman Islands, Canada, Bahamas.

Private jet with airstair door open on the apron

Aircraft Title and Liens

Resolving aircraft title encumbrances through strategic negotiation, legal counsel, and effective dispute resolution.

At the time of purchase and sale or in the event of dispute with a vendor or customer, encumbrances to the title of aircraft often occur. These encumbrances are often mechanic’s liens, fuel liens, and undischarged lender interests. We are well versed in the cost-effective discharge of these claims. We represent aircraft owners, lenders, repair facilities, and vendors in the lawful negotiation and litigation of such disputes.

FAA Certifications

FAA Certifications

Expert FAA guidance and legal support for efficient

aviation certification and compliance.

The follow through and attention to detail necessary to obtain FAA certification for maintenance facilities, charter operators, and flight schools can be a challenge. Our attorneys are familiar with the FAA and the unique considerations and time frames for obtaining certification. We look forward to working with you in your application and as a liaison with the FAA for Part 135 certification for on-demand charter operation, Part 145 Repair Station certification, and Part 141 flight school certification.

Aircraft in a hangar
Airport control tower at sunset

FAA Enforcement

FAA Enforcement

As members of the AOPA’s legal services panel,

Our attorneys are experienced with the defense of airmen, pilots, mechanics, aircraft owners, and repair facilities before the FAA and the NTSB. Our attorneys have represented airmen from the initiation of an FAA investigation through the NTSB hearing phase including emergency revocation proceedings. Our attorneys stand ready to diligently seek the best outcome.

Drones

Drones

Unmanned Aircraft Systems

SECTION 333 PETITION SUMMARY

By law, aircraft operating in the National Airspace System (NAS) generally require proper certification, registration, and pilot authorization. Section 333 of the FAA Modernization and Reform Act allows certain UAS operations to receive exemptions from applicable requirements. These exemptions are currently granted on a case-by-case basis, allowing qualified operators to conduct commercial UAS operations safely and legally. We assist clients in preparing and submitting Section 333 petitions.

Drone flying above the national airspace