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On March 21, 2025, FinCEN issued its promised Interim Final Rule (“IFR”) regarding reporting requirements under the Corporate Transparency Act (the “CTA”).1 As anticipated, FinCEN has removed beneficial ownership information (“BOI”) reporting requirements for all United States entities and United States persons.
The reporting requirements remain for foreign reporting entities that have registered to do business in any U.S. state or Tribal jurisdiction – although foreign reporting entities do not need to disclose their U.S. beneficial owners. Foreign reporting entities have thirty (30) days following the issuance of the IFR or following their registration to do business to file an initial BOI report, whichever is later.
FinCEN is now accepting comments on the IFR. Following receipt and consideration of comments, FinCEN intends to issue a final rule this year.
For the time being, it appears that both U.S. and foreign entities have clarity concerning their reporting obligations. However, there is likely still more to come between comments on the IFR, the issuance of a final rule, and pending litigation and legislation. As a result, our current posture may prove to be only a way station rather than our final stop.
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1 https://fincen.gov/news/news-releases/fincen-removes-beneficial-ownership-reporting-requirements-us-companies-and-us
The information contained herein is intended as a general overview and should not be construed as legal advice. Readers should not act upon it without professional counsel and should seek advice applicable to their specific situation.
Disclaimer:
This presentation has been prepared by Market Street Trust Company. The views expressed herein represent opinions of Market Street and are presented for informational purposes only. They are not intended to be recommendations or investment advice and do not take into account the individual financial circumstances or objectives of the investor who receives them.
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