It might surprise you the U.S. Census Bureau’s Foreign Trade Regulations (15 CFR §30.26) requires filing in the Automated Export System (AES) in certain circumstances even if your aircraft is to be and remain N registered.
Aside from military aircraft (as classified under ECCN 9A610.a or .b), an AES filing is required for non-military aircraft that are valued over US$25,000 and will be outside the US for more than twelve (12) months.
There has been some confusion both in the industry and in the government whether AES filings were required for aircraft that retain an N registration via trust ownership. Thankfully, there is finally guidance from the U.S. Census Bureau.
If you own an N registered aircraft that spends a significant portion of its time outside the US, give us a call and we can help you determine if an after-the-fact-filing is necessary.
