On Friday, March 21, the Financial Crimes Enforcement Network (FinCen) of the U.S. Treasury announced new rules governing the beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act. These new rules significantly narrow the field of entities required to report.
The BOI reporting saga has been a roller coaster of deadlines and delays, with legal injunctions and appeals leaving businesses confused about their actual reporting obligations. FinCen had promised new rules by March 21 and made good on that promise.
Under the new rules, entities formed under state law in the U.S. do not have to report their beneficial ownership information. Entities formed in foreign jurisdictions that do not meet one of the filing exceptions will have an additional 30 days to report, but they no longer have to report any information on their U.S. beneficial owners and U.S. persons do not have to provide their information to foreign reporting companies in which they own an interest.
If you have any questions about how these new rules affect your reporting obligations, don’t hesitate to contact us.