As announced in a Treasury release earlier this month (see related post), FinCEN has issued an interim final rule narrowing the scope of reporting required under the Corporate Transparency Act. The interim final rule removes the requirement for U.S. companies and U.S. persons to report beneficial ownership information (BOI) to FinCEN.
The interim final rule revises the definition of “reporting company” to mean only those entities that are formed under the law of a foreign country and that have registered to do business in any U.S. State or Tribal jurisdiction by the filing of a document with a secretary of state or similar office (formerly known as “foreign reporting companies”). FinCEN also exempts entities previously known as “domestic reporting companies” from BOI reporting requirements.
Foreign entities that meet the new definition of a “reporting company” and do not qualify for an exemption from the reporting requirements must report their BOI to FinCEN under new deadlines, which are included in the full release. These foreign entities, however, will not be required to report any U.S. persons as beneficial owners, and U.S. persons will not be required to report BOI with respect to any such entity for which they are a beneficial owner.
Resources:
Subscribe to Receive FinCEN Updates
FinCEN BOI Informational Brochure
FinCEN BOI Informational Videos
Small Entity Compliance Guide for BOI Reporting Requirements
Related Posts:
Treasury Provides Indefinite BOI Relief for Domestic Reporting Entities
FinCEN Halts Fines, Penalties and Enforcement Pending Final BOI Reporting Rule
ALERT: BOI Filing Requirements Reinstated (Again)
FinCEN BOI Filing Is Not Required Amid a Flurry of Year-End Rulings
ALERT: BOI Filing Requirements Restored with Extended Deadlines
UPDATE: Temporary Suspension of FinCEN BOI Filing Deadline
FinCEN BOI Filing Deadline is Rapidly Approaching
Federal CTA – Beneficial Ownership Reporting – Updates to FAQs
