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 and manager by manager, 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-front citizenship test an LLC has to pass, the documentation the registry requires, what non-citizen owners can do when the LLC fails the test, 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 a qualifying LLC as a citizen under the corporation-or-association framework — which is exactly why LLCs get extra paperwork. The non-citizen route in the third bullet is different: 14 CFR 47.3(a)(3) and 47.9 are written for a corporation (the application calls for a certified copy of its certificate of incorporation), so an LLC that fails the citizenship test can’t use it. 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:
- the entity is organized under the laws of the U.S. or a state;
- 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;
- 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 measures every LLC on two fronts. The FAA’s LLC information sheet says the members’ citizenship is measured against the statutory definitions and the management structure against the corporate test:
- Members. Each member’s citizenship and voting share count toward the 75% test. A member-managed LLC whose members are all individual U.S. citizens meets both fronts on its face, without any real percentage math. This is most single-plane LLCs.
- Management. Whoever runs the company (the members, a manager, or officers) has to meet the citizen-president and two-thirds requirement, and the FAA says a non-citizen member or manager may not act independently in a management capacity. So all-citizen members with a non-citizen manager can still fail. Add a non-citizen member and the percentages start to bite: 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 LLC submits one of two things:
- a copy of its organizing document (certificate of formation, articles of organization, or operating agreement) that names each member and says whether the members, a manager, or officers run the company, plus the citizenship of each member, manager, or officer (a cover letter or separate statement is fine); or
- the FAA’s signed Statement in Support of Registration of U.S. Civil Aircraft in the Name of an LLC, made by someone with knowledge of the facts.
The statement form asks for:
- the LLC’s full legal name and the state and date of organization;
- every member, with each member’s entity type (individual, corporation, partnership, another LLC), citizenship, and ownership share;
- whether the company is managed by its members, managers, or officers, and the name and citizenship of each manager or officer;
- whether they may act independently (a non-citizen member or manager may not);
- a signed affirmation that the LLC is organized under U.S. or state law, that at least two-thirds of its managers are U.S. citizens, and that U.S. citizens own or control at least 75% of the voting interest.
If management changes later (say, from member-managed to manager-managed), the LLC must give the Registry written notice of the change and its effective date.
How registration actually works, step by step
- 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
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 citizenship documentation described above (organizing document plus citizenship, or the signed LLC statement). 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
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
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 non-citizen routes
Plenty of legitimate owners fail the 47.2 test — a foreign entrepreneur with a U.S. business, a U.S. LLC with 50/50 citizen and non-citizen members. An LLC in that position can’t register the aircraft in its own name: Part 47’s non-citizen ownership route (14 CFR 47.3(a)(3) and 47.9) is written for corporations, not LLCs. Short of restructuring the LLC so it qualifies, that leaves two doors, and they’re genuinely different: hold the aircraft in a non-citizen U.S. corporation instead, or put it in an owner trust.
| Ownership path | Core requirement | Paperwork beyond AC Form 8050-1 | Watch-outs |
|---|---|---|---|
| Individual | U.S. citizen, or resident alien (green card) | Evidence of ownership + $5 | Your name and address on the public registry; no liability wall around the aircraft |
| LLC as a U.S. citizen | Citizen president and 2/3 citizen managers, actual citizen control, and 75% citizen voting interest (14 CFR 47.2); an all-citizen, member-managed LLC passes on its face | Organizing document plus each member’s and manager’s citizenship, or the FAA’s signed LLC statement | Entity members are analyzed all the way down; resident-alien members and managers count as non-citizens |
| Non-citizen U.S. corporation (not an LLC) | A corporation organized and doing business under U.S./state law; aircraft based and primarily used in the U.S. — at least 60% of flight hours (14 CFR 47.9) | Certified copy of the certificate of incorporation, certification that it may do business in a state and that the aircraft is U.S.-based, and where flight records are kept | Means a corporation owns the aircraft instead of the LLC; flight-hour reports every six months, records kept three years for FAA inspection; mostly-international flying breaks the 60% |
| Non-citizen owner trust | Every trustee a U.S. citizen or resident alien; non-citizens capped at 25% of the power over the trustee (14 CFR 47.7(c)) | Trust instrument and related documents, plus beneficiary-citizenship or trustee affidavits | Professional trustee fees; the FAA reviews trust terms; operational control still needs careful papering |
The non-citizen corporation route (14 CFR 47.9) works when the owner is willing to hold the aircraft in a corporation rather than an LLC and the flying is genuinely domestic. The corporation 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 corporation 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 (the address shown is whatever mailing address the LLC registers, so an LLC at your home address still shows your home), and since March 28, 2025 owners of privately operated aircraft can separately ask the FAA to withhold their name and address from public display on FAA websites 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 FAA citizenship showing 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 non-citizen ownership structures 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
Can an LLC register an aircraft with the FAA?
What is the FAA LLC statement?
What if a member of my LLC is not a U.S. citizen?
What is a non-citizen owner trust for aircraft?
How much does FAA aircraft registration cost, and how long does it last?
Can I fly the plane while the FAA processes the registration?
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 Aircraft Registry — Statement in Support of Registration of U.S. Civil Aircraft in the Name of an LLC (form)
- 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)
- FAA Exemption No. 7897N (NBAA Small Aircraft Exemption, through Mar. 31, 2028), Docket FAA-2002-12728
This guide is general information, not legal advice. FilingDesk is not a law firm.