2025 Update on the Corporate Transparency Act
On March 21, 2025, FinCEN issued an interim final ruling regarding the reporting requirements for Beneficial Ownership Information (BOI) under the Corporate Transparency Act (CTA).
- FinCEN narrowed the scope of beneficial ownership information filing requirements to foreign entities only. A company is required to file if the entity is formed under the laws of a foreign country and have registered to do business in a U.S. state.
- FinCEN removed the requirement for U.S. companies and U.S. persons to file a BOI if the entity was formed in the U.S. If you are a domestic entity, you do not have to file.
- This interim final ruling also exempts any foreign reporting entities from having to report the BOI of any U.S. persons who are beneficial owners and exempts U.S. persons from having to provide such information to any foreign reporting company for which they are a beneficial owner.
For more information on the 2025 update to the Corporate Transparency Act visit the FinCEN website at https://www.fincen.gov/boi. There you can find information regarding whether your small business entity is required to file, how to file, and a link to the BOIR online filing system.
We are happy to answer questions our clients may have regarding this update. However, since this filing is considered a legal matter, it is best to contact an attorney in any conversation regarding the potential filing.