Another Corporate Transparency Act Update

Another Corporate Transparency Act Update:

Whipsaw:

On March 21, 2025, the Financial Crimes Enforcement Network (“FinCEN”) issued another “interim final” rule removing the requirement for U.S. companies and U.S. persons to report beneficial ownership information (“BOI”) to FinCEN under the Corporate Transparency Act (“CTA”).

Now only foreign companies (not U.S. companies owned by non-U.S. persons) that have registered to do business in the U.S. will be required to comply with the CTA.  So, now it is only Foreign entities that meet the new definition of a “reporting company,” and which do not qualify for an exemption from the reporting requirements, that must report their BOI to FinCEN.  These foreign entities 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.  The new deadlines are:

  • •Reporting companies registered to do business in the United States before March 21, 2025, must file BOI reports no later than 30 days from that date.

  • •Reporting companies registered to do business in the United States on or after March 21, 2025, have 30 calendar days to file an initial BOI report after receiving notice that their registration is effective.

For further information on the CTA, please see our website or contact dawn@eppscoulson.com.

Information contained in this Memo is intended for informational and educational purposes only and does not constitute legal advice or opinion, nor is it a substitute for the professional judgment of an attorney.  It is likely considered advertising.  Epps & Coulson, LLP encourages you to call to discuss these matters as they apply to you or your business.  Epps & Coulson, LLP has staff licensed in France and affiliated Counsel offices in New York and Connecticut with lawyers also admitted in Connecticut, District of Columbia Massachusetts (pending), New Jersey, Hawaii, European Union, England and Wales, France (Paris Bar) and Sweden.

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