Corporate Transparency Act (CTA)
On March 21, 2025, the Financial Crimes Enforcement Network of the U.S. Treasury Department (FinCEN) narrowed the scope of the beneficial ownership information (BOI) filing requirement under the Corporate Transparency Act to exempt all companies formed in the United States from the BOI filing requirement. FinCEN’s new interim final rule requires only “foreign reporting companies” – foreign entities registered to do business in the United States by filing of a document with a secretary of state or a similar office – to file BOI reports. In addition, foreign reporting companies are not required to report any beneficial owners who are citizens or residents of the United States (U.S. persons), and U.S. persons are not required to report BOI with respect to any foreign reporting company for which they are a beneficial owner.
