Ryan J. McDonell, CPA, MSA, MSLT
Tax Director

The Financial Crimes Enforcement Network (FinCEN) has issued an interim final rule that exempts U.S. companies and U.S. persons from reporting beneficial ownership information (BOI) under the Corporate Transparency Act.

The exemption applies to all entities created in the U.S. and their beneficial owners under the interim rule announced on March 21, 2025.
The interim rule changes the definition of a “reporting company” to mean only foreign entities, which are companies formed under the laws of a foreign country that have registered to do business in the U.S.

Foreign entities must comply within 30 days from either the rule’s publication in the Federal Register, or from the effective date of their U.S. registration. U.S. persons associated with these foreign entities are not currently required to report.

FinCEN is accepting comments on this interim rule and intends to finalize the rule this year.

The Treasury Department previously announced in early March it would not enforce any penalties or fines against U.S. citizens or domestic reporting companies or their beneficial owners for noncompliance with BOI. FinCEN had also announced it would not issue any fines or penalties or take enforcement action against companies for failure to file or update BOI reports by the current deadline.

What does this mean for your company?

If your entity was established in the U.S. under the laws of the U.S., and its beneficial owners are U.S. persons (meaning U.S. citizens and lawful permanent residents), you have no BOI reporting obligation.

We will keep you informed of any further developments.