UPDATE: U.S. Companies and U.S. Persons are Exempt from the Corporate Transparency Act’s Beneficial Ownership Information Reporting Requirements

By: Margaret Karakashian, Esq. 

The Financial Crimes Enforcement Network (“FinCEN”) has issued an interim final rule which removes the beneficial ownership information (“BOI”) filing requirement for U.S. companies and U.S. persons. Further, the interim final rule exempts foreign reporting companies from providing BOI for any beneficial owners who are U.S. persons.

Foreign entities that meet the definition of a reporting company and do not qualify for an exemption from the BOI reporting requirements will have to report BOI with respect to their non-U.S. beneficial owners. A reporting company for this purpose is defined as any entity that is “a) a corporation, limited liability company, or other entity; b) formed under the law of a foreign country; and c) registered to do business in any State or tribal jurisdiction by the filing of a document with a secretary of state or any similar office under the law of that State or Indian tribe.” The deadline to report BOI for such existing entities is April 25, 2025 (for most companies) and for newly registered entities, within 30 calendar days of registering to do business in the United States. 

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