News & Analysis as of

Interim Final Rules (IFR) Foreign Corporations

Troutman Pepper Locke

Practical Implications of the Interim Final Rule for BOI Reporting Under the CTA

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As we previously discussed, the Financial Crimes Enforcement Network (FinCEN) published an interim final rule (IFR) on March 26 that narrowed the beneficial ownership information (BOI) reporting requirements under the...more

Pillsbury Winthrop Shaw Pittman LLP

CTA Deadline Approaching for Foreign Reporting Companies

The Corporate Transparency Act (CTA) was adopted by Congress in January 2021 and became effective on January 1, 2024. Under the CTA and the initial regulations implementing it, “reporting companies” (corporations, LLCs,...more

PilieroMazza PLLC

Corporate Transparency Act, Part 10: Interim Final Rule, U.S. Companies and U.S. Persons Exempt From Reporting

PilieroMazza PLLC on

On March 26, 2025, FinCEN issued an interim final rule and request for comments, removing the requirement under the Corporate Transparency Act (CTA) for both U.S. companies and U.S. persons to report beneficial ownership...more

Patterson Belknap Webb & Tyler LLP

FinCEN Issues Interim Final Rule Under the Corporate Transparency Act

On March 21, 2025, FinCEN released an interim final rule (the “Interim Final Rule”) that exempts domestic reporting companies and U.S. persons from being required to report beneficial ownership and company applicant...more

Holland & Knight LLP

Interim Final Rule Clarifies Tribal Entities Not Subject to Corporate Transparency Act

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The Financial Crimes Enforcement Network (FinCEN), a unit of the U.S. Department of the Treasury charged with administering the Corporate Transparency Act (CTA), issued an interim final rule on March 21, 2025, that exempts...more

Lathrop GPM

U.S. Entities and U.S. Persons Are No Longer Required to Make CTA Filings under CTA Interim Final Rule

Lathrop GPM on

Consistent with our expectations as reported in our last Legal Update dated March 4, 2025, on March 26, 2025, the United States Department of the Treasury Financial Crimes Enforcement Network (“FinCEN”) published an interim...more

ArentFox Schiff

CTA Drastically Pared Back

ArentFox Schiff on

As promised by the US Department of Treasury in early March, the Financial Crimes Enforcement Network (FinCEN) issued an interim final rule removing the requirement for US companies, their beneficial owners, and US persons to...more

Fenwick & West LLP

The Corporate Transparency Act: FinCEN Removes Reporting Reqs for US Companies and Persons, Sets New Deadlines for Foreign...

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In a press release issued on March 21, 2025, FinCEN issued an interim final rule (IFR) revising the definition of “reporting company” to mean only those entities formed under the laws of a foreign country that have registered...more

Bodman

U.S. Companies and Business Owners Exempted from CTA Reporting Requirements

Bodman on

The Financial Crimes Enforcement Network (“FinCEN”) has issued an interim final rule that would exempt U.S. companies and U.S. persons from reporting their beneficial ownership information (“BOI”) as part of the Corporate...more

Bracewell LLP

FinCEN Adopts Interim Final Rule Limiting CTA Reporting Requirements to Foreign Reporting Companies

Bracewell LLP on

US legal entities are no longer subject to the reporting requirements of the Corporate Transparency Act (CTA). On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN), a bureau of the US Department of Treasury...more

McNees Wallace & Nurick LLC

Closing Call for the Corporate Transparency Act: FinCEN Removes Reporting Requirements for Domestic Business Entities

After almost fifteen months of legal challenges, conflicting court rulings, changing guidance from the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN), and a general air of uncertainty, it appears...more

Smith Anderson

Corporate Transparency Act NARROWED - FinCEN Eliminates Reporting Obligations for All U.S. Persons and U.S. Entities

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As we noted in our most recent client alert, on February 27, 2025, the Financial Crimes Enforcement Network ("FinCEN") announced that it would halt all enforcement of the Corporate Transparency Act (the "CTA") and issue an...more

Vinson & Elkins LLP

FinCEN Issues Interim Final Rule – BOI Reporting Obligations Narrowed to Foreign Reporting Companies and New Deadlines Issued

Vinson & Elkins LLP on

As we previously discussed and in alignment with the U.S. Treasury Department’s previous announcement, on March 21, 2025, the Financial Crimes Enforcement Network (“FinCEN”) issued an interim final rule that dramatically...more

Moritt Hock & Hamroff LLP

Important Update On The Corporate Transparency Act: FinCEN Issues Interim Final Rule

On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) issued a new interim final rule that removes the beneficial ownership information (BOI) reporting requirements for U.S. companies and U.S. persons. The rule...more

White and Williams LLP

Corporate Transparency Act – FinCEN Narrows Scope of Reporting Requirements and Extends Deadline

White and Williams LLP on

In the latest twist in the ongoing Corporate Transparency Act (“CTA”) and beneficial ownership information (“BOI”) reporting requirements saga, news came from Washington on March 21, 2025, that the Financial Crimes...more

Ward and Smith, P.A.

Corporate Transparency Act Shakeup: Domestic Companies off the Hook, Foreign Entities Still Reporting

Ward and Smith, P.A. on

This interim final rule, released on March 21, 2025, means that only foreign entities registered to do business in the United States will still need to meet the CTA’s reporting requirements. Originally enacted to increase...more

Montgomery McCracken

Corporate Transparency Act No Longer Applies to Entities Formed in the U.S.

Montgomery McCracken on

On March 26, 2025, the Financial Crimes Enforcement Network (“FinCEN”), a division of the United States Department of the Treasury, published in the Federal Register an interim final rule that substantially narrows the...more

WilmerHale

Corporate Transparency Act: FinCEN Suspends BOI Reports for U.S. Companies and Persons, Sets New Filing Deadlines for Foreign...

WilmerHale on

On Friday, March 21, 2025, FinCEN issued an interim final rule (“IFR”) eliminating beneficial ownership information (“BOI”) reporting requirements for U.S. companies and U.S. persons under the Corporate Transparency Act...more

Parker Poe Adams & Bernstein LLP

Scope of Corporate Transparency Act Dramatically Narrowed Under New Rule

In an interim final rule (IFR) announced March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) dramatically narrowed the scope of the Corporate Transparency Act (CTA). Under the IFR, which is effective...more

Bailey & Glasser, LLP

Client Alert: "BOI Reporting Dropped for U.S. Entities; 30-Day Extension for Foreign Companies"

Bailey & Glasser, LLP on

In the latest turn of events in the ever-evolving reporting rule saga under the Corporate Transparency Act (“CTA), on March 21, 2025, FinCEN issued an Interim Final Rule (“IFR”) and accompanying press release, aligning with...more

Holland & Hart LLP

FinCEN EXEMPTS U.S. Companies and U.S. Persons from CTA Reporting Requirements

Holland & Hart LLP on

The Corporate Transparency Act (together with its implementing regulations, the CTA) is a federal law that went into effect on January 1, 2024. The CTA is aimed at combating financial crimes such as money laundering,...more

Proskauer Rose LLP

New Interim Rule Removes CTA Reporting Requirements for U.S. Companies and U.S. Persons

Proskauer Rose LLP on

On March 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued an interim final rule to the U.S. Corporate Transparency Act (“CTA”) that eliminates beneficial ownership...more

Troutman Pepper Locke

CTA Significantly Amended by Interim Final Rule

Troutman Pepper Locke on

On March 21, the Financial Crimes Enforcement Network (FinCEN) submitted an interim final rule (IFR) to the Federal Register, regarding the beneficial ownership information (BOI) reporting requirements under the Corporate...more

Benesch

Domestic BOI Reporting Requirements Ended; Foreign Companies Must Still Report

Benesch on

On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) issued an interim final rule removing the requirement for U.S. companies and U.S. persons to report beneficial ownership information (BOI) under the...more

BCLP

FinCEN Eases CTA Reporting Rules: U.S. Companies Get a Pass, Foreign Entities Get a Breather

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As previewed by FinCEN and Treasury earlier this month, FinCEN announced major changes to the application of the Corporate Transparency Act. On Friday evening, FinCEN issued an interim final rule that will remove the...more

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