FinCEN Issues Interim Final Rule Limiting Application of Corporate Transparency Act's Reporting Rule to Foreign Reporting Companies and Amends the Deadline for Foreign Reporting Companies to File Reports

On March 21, 2025, FinCEN issued an interim final rule limiting the application of beneficial ownership information filing requirements to foreign reporting companies.  Domestic companies are no longer required to make filings with FinCEN and are instead exempt. 

Foreign reporting companies must still comply with the Corporate Transparency Act's filing requirements. However, they are not required to submit information about their beneficial owners who are United States persons, nor do such U.S. beneficial owners of foreign reporting companies have to submit their information to foreign reporting companies. 

With the interim final rule, FinCEN has also extended the deadline for foreign reporting companies to make filings.  A foreign reporting company must now submit its initial beneficial ownership report and update or correct previously filed beneficial ownership information reports within 30 days from publication of the March 21st interim final rule or 30 days after the reporting company's registration to do business in the United States, whichever comes later. 

The attorneys here at Stone Pigman are following the latest developments regarding the Corporate Transparency Act and will provide further updates as pertinent information becomes available.

Last Updated March 25, 2025