Common Sense Prevails! Interim Final Rule Issued for The Corporate Transparency Act

The Treasury Department announced on March 21 that it has suspended the enforcement of the Corporate Transparency Act against U.S. citizens and domestic reporting companies. This narrows the scope of the rule to foreign reporting companies only. This rule is effective March 26, 2025. Written comments must be received on or before May 27, 2025.

Under this interim final rule for the Corporate Transparency Act, entities previously defined as “domestic reporting companies” are exempt from the reporting requirements and do not have to report Beneficial Ownership Information to FinCEN or update or correct BOI previously reported to FinCEN.

With limited exceptions, the interim final rule does not change the existing requirement for foreign reporting companies to file BOI reports, but it extends the deadline to file initial BOI reports and to update or correct previously filed BOI reports to 30 days from the date of the Treasury Department’s publication to give foreign reporting companies additional time to comply. However, the interim final rule exempts foreign reporting companies from having to report the BOI of any U.S. persons who are beneficial owners of the foreign reporting company and exempts U.S. persons from having to provide such information to any foreign reporting company for which they are a beneficial owner. 

FinCEN is accepting comments on this interim final rule. FinCEN will assess the exemptions, as appropriate, and intends to issue a final rule this year.