Aviation law is a highly specialized field of law that encompasses most facets of air travel, as well as the operation and regulation of business issues relating to air travel. Practicing aviation law requires a comprehensive knowledge of FAA regulations, specific laws regarding flight, and an in-depth understanding of the industry. It also pertains to the challenges and representation of aircraft owners with respect to personal property tax assessments by the state and local governments.
Shareholder C. Bruce Willis, II chairs the Aviation Law practice of the Firm. Mr. Willis formerly acted as general counsel for a privately held company that owned, leased and chartered commercial aircraft.
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On March 21, 2024, the Financial Crimes Enforcement Network (FinCEN) issued an interim final rule that significantly narrows the scope of beneficial ownership information (BOI) reporting requirements.
Under the revised rule, only companies formed under the law of a foreign country and registered to conduct business in the United States are considered “reporting companies” subject to the Corporate Transparency Act (CTA) BOI filing requirements.
The revised rule removes the requirement that U.S. companies and U.S. persons report BOI to FinCEN. The rule also removes the requirement that foreign companies report BOI for U.S. persons. Additionally, the rule extends the previously set March 21, 2025, BOI report filing deadline by 30 days, and requires newly registered foreign companies to file a BOI report within 30 days after receiving notice that their registration is effective.
Although the interim rule is effective immediately, FinCEN has implemented a 60-day public comment period, and intends to issue a final rule before the end of the year.
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