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ARTICLE · 27 MARCH 2025

FinCEN Issues Interim Final Rule Gutting The Corporate Transparency Act

Foley Hoag LLP
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On March 21, 2025, the Financial Crimes Enforcement Network ("FinCEN") of the U.S. Department of the Treasury issued an interim final rule ("IFR")...

United StatesCorporate/Commercial Law
Michael Glanz
Michael Glanz
Luciano Racco
Luciano Racco
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Key Takeaways:

  • Exemption for Domestic Reporting Companies: Domestic reporting companies are now exempt from the requirement to file beneficial ownership information ("BOI") reports under the Corporate Transparency Act ("CTA").
  • Exemption for Foreign Reporting Companies with beneficial owners who are all U.S. persons: Foreign reporting companies are exempt from reporting the BOI of U.S. persons who are beneficial owners, and U.S. persons are exempt from providing such information.
  • Extended Deadlines for Foreign Reporting Companies: Foreign reporting companies who have non-U.S. person beneficial owners have until April 25, 2025, to file initial BOI reports or update/correct previously filed reports.

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