FAA aircraft registration when an LLC owns the plane

The FAA will register your airplane for $5. What it will not do is register it to just anyone: 14 CFR Part 47 restricts U.S. registration to owners who qualify — and when the owner is an LLC, the registry demands proof that the company itself is a “citizen of the United States,” member by member, all the way down the ownership chain. The $5 is the easy part; the citizenship showing is the real filing.

This guide walks the whole federal layer: who may register under Part 47, the two citizenship tests an LLC can pass, the LLC statement the registry requires, the non-citizen entity and owner-trust routes when the tests fail, the actual forms and fees, and the renewal clock. It’s general information, not legal advice — FAA citizenship opinions and trust structures are aviation-attorney work, and a registration built on a defective citizenship showing is a problem that surfaces at the worst possible time, usually in front of a lender or an insurer.

Who the FAA lets register an aircraft

Under 14 CFR 47.3, a U.S.-registered civil aircraft must be owned by one of four kinds of person — and with narrow exceptions (temporary authority, military aircraft), nobody may operate an eligible aircraft in the U.S. until it’s registered:

• a citizen of the United States — an individual citizen, a partnership in which every partner is an individual citizen (corporate partners disqualify a partnership outright under 14 CFR 47.7), or a corporation or association that passes the entity citizenship test below;
• an individual resident alien — a citizen of a foreign country lawfully admitted for permanent residence in the U.S.;
• a non-citizen corporation organized and doing business under U.S. or state law, but only while the aircraft is based and primarily used in the United States; or
• a government unit — the United States, a state, territory, or political subdivision.

An LLC isn’t named in that list, but the FAA registers LLCs under the corporation-or-association framework — which is exactly why LLCs get extra paperwork. A corporation’s officers and directors are on the public record; an LLC’s membership structure is whatever its operating agreement says it is, so the registry makes you spell it out.

One more thing worth knowing before the closing table gets passed around: under 14 CFR 47.5, an aircraft may be registered only by and in the legal name of its owner, and federal law (49 U.S.C. 44103(c)) is explicit that registration is not evidence of ownership in any proceeding. The FAA registry is not a title system — which is why serious purchases run a title search on the aircraft’s FAA records and close through escrow.

The citizenship test an LLC has to pass

14 CFR 47.2 defines a corporate “citizen of the United States” with three cumulative requirements, and the FAA applies the same framework to LLCs:

1. the entity is organized under the laws of the U.S. or a state;
2. its president and at least two-thirds of the board of directors and other managing officers are U.S. citizens — for an LLC, read “managing officers” as its managers or managing members;
3. it is under the actual control of U.S. citizens, and U.S. citizens own or control at least 75% of the voting interest.

In practice the registry recognizes two ways an LLC qualifies:

• The clean basis: every member is a U.S. citizen. A member-managed LLC whose members are all individual U.S. citizens qualifies without touching the percentage math. This is most single-plane LLCs.
• The corporate-style test. Add a non-citizen member and the LLC must satisfy the full 47.2 test — two-thirds citizen managers, actual control, 75% citizen voting interest. Workable, but now the operating agreement’s voting and control provisions are federal compliance documents, and “actual control” is a facts-and-circumstances judgment the FAA can probe.

The LLC statement: what the registry actually wants

Along with the registration application, the FAA requires every LLC applicant to document its structure — the registry’s LLC information sheet is the controlling reference. The showing can come from the LLC’s organizing documents or from a signed statement in support of registration, and it must establish:

• the LLC’s full legal name and the state and date of organization;
• every member, and each member’s entity type (individual, corporation, another LLC, a trust);
• whether the company is member-managed or manager-managed, and who the managers are;
• how the LLC qualifies as a citizen of the United States — the all-citizen-members basis, or the 2/3-and-75% showing.

How registration actually works, step by step

1. 1

   Close with real evidence of ownership

   The registry wants the chain of title. For a typical purchase that’s the AC Form 8050-2 Aircraft Bill of Sale (or other evidence of ownership) from the seller to your LLC — in the LLC’s exact legal name, because 14 CFR 47.5 requires registration in the owner’s legal name. Buying an aircraft that’s already inside a seller’s LLC and buying the LLC itself are different transactions with different registration consequences — the second changes the LLC’s membership, which changes the citizenship analysis. Run either through an aviation escrow and title search.

2. 2

   File AC Form 8050-1 with the citizenship showing and $5

   The application package under 14 CFR 47.31 is the AC Form 8050-1 Aircraft Registration Application, the evidence of ownership, the $5 fee (14 CFR 47.17), and — for an LLC — the LLC statement described above. Applications go to the FAA’s Civil Aviation Registry, and the FAA’s CARES portal now accepts online submissions from individuals, corporations, and LLCs, with document upload replacing the paper mail loop. Want a specific N-number? Reserving a special registration number is $10.

3. 3

   Fly domestically on the second copy while you wait

   Under 14 CFR 47.31, the second copy of the application, carried in the aircraft, is temporary authority to operate within the United States until your certificate arrives or the FAA denies the application — and 14 CFR 91.203 recognizes it as the registration document for domestic flight. It is not valid for international operation: no Bahamas or Canada trips until the actual Certificate of Aircraft Registration is aboard.

4. 4

   Calendar the seven-year renewal

   Under 14 CFR 47.40, the certificate expires seven years after the last day of the month it was issued. Renewal is AC Form 8050-1B and another $5, filed during the six months before expiration. An expired registration grounds the aircraft just as thoroughly as no registration — put the date in the same compliance calendar as your annual and your LLC’s state filings.

Register

$5

AC Form 8050-1, per aircraft

Renew

$5

AC Form 8050-1B, 7-year cycle

Special N-number

$10

reserve or assign

Replacement certificate

$2

14 CFR 47.17

When the LLC can’t pass: the two non-citizen routes

Plenty of legitimate owners fail the 47.2 tests — a foreign entrepreneur with a U.S. business, a U.S. LLC with 50/50 citizen and non-citizen members. Part 47 gives them two doors, and they’re genuinely different.

The non-citizen U.S. entity route (14 CFR 47.9) works when the flying is genuinely domestic. The entity certifies that the aircraft will be based and primarily used in the United States — defined as at least 60% of total flight hours accumulated in the U.S., measured first over the registration month plus the six calendar months that follow, then over each successive six-month period. Only non-stop legs between two U.S. points count as U.S. hours (emergency and fuel stops excepted), the entity must keep flight-hour records for three calendar years after the year the hours were flown and produce them on FAA request, and at the end of each period it must file a signed flight-hour report (or a signed statement that all flying was within the U.S.). That’s a permanent operational leash — fine for a plane that lives and works here, wrong for an owner who flies internationally.

The non-citizen owner trust (14 CFR 47.7(c)) moves legal title to a trustee who does qualify — each trustee must be a U.S. citizen or resident alien — while the non-citizen keeps the beneficial interest. The application includes the trust documents plus affidavits: either that each beneficiary is a U.S. citizen or resident alien, or from each trustee that non-citizens together hold no more than 25% of the aggregate power to influence or limit the exercise of the trustee’s authority. And where non-citizens hold the power to direct or remove a trustee — directly or through control of another person — the regulation caps that power at the same 25% in aggregate, while expressly allowing non-citizens to hold more than 25% of the beneficial interest in the trust. This is a well-worn structure for foreign owners who want an N-number, typically run through a professional trustee company for a recurring fee — and it’s bespoke legal work, not a form off the internet.

What FAA registration doesn’t do

Three honest limits, because this page would be incomplete without them:

• It isn’t title. Registration is not evidence of ownership in any proceeding — buy through escrow, with a title search against the FAA records.
• It isn’t privacy, exactly. The registry is public and searchable by N-number: an LLC swaps your name for the company’s on every lookup, and since March 28, 2025 private owners can separately ask the FAA to withhold their personal information from public display under Section 803 of the FAA Reauthorization Act of 2024. State LLC records can still connect dots — Wyoming’s keep members off the public record, most states’ don’t.
• It isn’t tax planning. Sales, use, and property tax follow where the aircraft is based and flown — never the N-number’s paperwork or the LLC’s state. Some states also run their own aircraft registration on top of the FAA’s (Arizona’s is the classic example; Texas has none), and even Montana — famous for having no sales tax — doesn’t change what your hangar state charges.

Where FilingDesk fits

FilingDesk forms the LLC layer — the entity whose members, managers, and voting interests the FAA will read. Describe what you’re doing in plain English; we run the name check, prepare and file the formation documents with a human specialist reviewing every filing, then handle the EIN and generate an operating agreement that puts your membership and management structure on paper — the exact facts your LLC statement has to recite. $99 flat plus the state fee: Wyoming $199 all-in, Delaware $209, Florida $224, no upsells.

What we don’t do is FAA practice: citizenship opinions, owner trusts, dry leases, and 47.9 reporting belong with an aviation attorney. The working order that saves the most grief: settle the ownership and operating structure with counsel, form the entity to match it, then file the 8050-1 — in that order, once.

FilingDesk is not a law firm and does not provide legal or tax advice. This guide is general information only; consult a licensed aviation attorney and a CPA about your specific aircraft and situation.

Frequently asked questions

Sources

• eCFR — 14 CFR Part 47, Aircraft Registration (eligibility, citizenship, trusts, fees, duration)
• FAA Aircraft Registry — Limited Liability Companies info sheet (LLC statement requirements)
• FAA — Civil Aviation Registry Electronic Services (CARES) online filing
• eCFR — 14 CFR 91.203 (certificates required aboard the aircraft)
• eCFR — 14 CFR 119.1 (when an air carrier / commercial operator certificate is required)
• eCFR — 14 CFR 91.501 (cost-sharing options for large and turbojet airplanes)
• FAA — Request to Withhold Aircraft Ownership Data (registry privacy, from March 2025)
• NBAA — Small Aircraft Exemption (extends 91.501 cost-sharing options to small aircraft)

This guide is general information, not legal advice. FilingDesk is not a law firm.