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Legal Update – Corporate Transparency Act

Beneficial Reporting Requirement Abandoned for U.S. Companies (At Least For Now!)

The Corporate Transparency Act (CTA) went into effect on January 1, 2024, and would have required all non-exempt companies to report Beneficial Ownership Information (BOI) about the individuals who ultimately own or control them to the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN). This would have applied to almost every small and medium-sized business formed as a corporation, limited liability company (LLC), limited partnership, limited liability partnership, or similar entity.

After subsequent litigation and a change of administrations, the CTA has been substantially limited in scope so that it now only applies to foreign companies. Specifically, on March 2, 2025, the U.S. Department of Treasury announced that it will not enforce the CTA against U.S. citizens and domestic reporting companies and their beneficial owners under the current reporting rules as well as under anticipated rule changes to the CTA reporting requirements.

So, for the time being at least, domestic companies have no obligation to comply with the CTA beneficial ownership information reporting requirements.