Legal Interpretations
Lane 1994
Summary
The Question
May a U.S. corporation that is a wholly-owned subsidiary of a Canadian corporation hold a 14 CFR part 133 Rotorcraft External-Load Operator Certificate?
Background
An attorney asked whether a U.S. corporation wholly owned by a Canadian corporation could obtain an operating certificate under 14 CFR part 133.
The FAA’s Interpretation
Yes. After reviewing 14 CFR part 133 and its regulatory history, the FAA found no prohibition against the U.S. corporation holding a Rotorcraft External-Load Operator Certificate.
- Requester
- Lane
- Issued
- April 11, 1994
- Subject
- General
Regulations Cited
Page 1
April 11, 1994
James L. Lane, Esq.
Dear Mr. Lane:
This is in response to your letter of April 7, 1994. You requested our opinion as to whether a U.S. corporation, which is a wholly-owned subsidiary of a Canadian corporation, may obtain an operating certificate under Part 133 of the Federal Aviation Regulations.
We have reviewed Part 133 and its regulatory history and find no prohibition against the U.S. corporation from holding a Part 133 Rotorcraft External-Load Operator Certificate. Please contact us if we may provide you with further assistance.
Sincerely yours,
John J. Callahan
Deputy Assistant Chief Counsel
Regulations Referenced
Snapshot retrieved August 6, 2026.