Managing Partner
Following the US Treasury Department’s statement that it would not enforce Beneficial Ownership Information (BOI) reporting requirements, FinCEN has announced that it will issue an interim final rule removing the BOI reporting requirements for U.S. persons and U.S. companies from the Corporate Transparency Act (CTA).
Under this interim final rule, BOI reporting will only be required for entities formed under the law of a foreign country that have filed with a secretary of state or similar office to do business in the any state or tribal jurisdiction in the United States. Entities created in the United States will be exempt from any reporting requirements. Additionally, foreign entities will not be required to report any U.S. persons as beneficial owners of such entities.
Existing foreign reporting companies that have registered to do business in the United States prior to the publication of the interim rule will have 30 calendar days from the date of publication to comply with BOI reporting requirements. Foreign reporting companies registering after publication of the rule will have 30 calendar days from the effective date of registration to file an initial BOI report.
Please contact our Firm with questions or for additional information.
