Estate and Succession Planning
Dean Mead’s Estate and Succession Planning Department is one of the largest and most respected groups of estate planning attorneys in Florida. We are frequently…
Published: March 26, 2025
On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) issued an interim final rule, effective March 26, 2025, which modified certain aspects of the Corporate Transparency Act (CTA) reporting requirements.
The rule introduced key changes, including exemptions for domestic reporting companies and adjustments to reporting obligations for foreign entities:
Exemption for Domestic Reporting Companies – Domestic reporting companies are now exempt from the CTA’s beneficial ownership information (BOI) reporting requirements. They are no longer required to disclose this information to FinCEN.
Reporting Requirements for Foreign Reporting Companies – Foreign reporting companies will be required to provide BOI information for their beneficial owners who are not U.S. persons. Additionally, U.S. persons are not required to provide a foreign reporting company with BOI information. Foreign reporting companies, which are defined as companies formed in a foreign country who are registered with a U.S. state to conduct business, will still be required to report beneficial ownership information of their non-U.S. beneficial owners.
Extended Reporting Deadlines – FinCEN has extended the reporting deadline for foreign reporting companies by an additional 30 days from the date of publication of the interim rule (defined as March 26, 2025) which will extend their filing dates to April 25, 2025.Exemption for Domestic Reporting Companies – Domestic reporting companies are now exempt from the CTA’s beneficial ownership information (BOI) reporting requirements. They are no longer required to disclose this information to FinCEN.
Background
The CTA, enacted in 2021, aimed to enhance transparency in corporate structures by requiring entities to report their beneficial owners to FinCEN. Prior to the current rule, the reporting requirements faced legal challenges, leading to temporary halts.
Next Steps
FinCEN is accepting public comments on the interim final rule for 60 days. A final rule is expected to be issued in 2025 which may further refine reporting requirements.
