Client Notice: United States Department of Treasury Eliminates Corporate Transparency Act Filing Requirements for US Reporting Companies and US Citizens and Residents

On March 21, 2025 the United States Department of Treasury announced that companies incorporated in a U.S. state, known as “U.S. reporting companies,” and citizens and residents of the United States are no longer subject to the filing requirements of the Corporate Transparency Act (CTA.)

The Treasury Department’s announcement eliminates the need for any U.S. reporting companies to file a Beneficial Ownership Information Report (BOIR,) or file any BOIR updates with the United States Department of Treasury Financial Crimes Enforcement Network (FinCEN.)

The Treasury Department also announced that the CTA’s filing requirement continues to apply to “foreign reporting companies,” although in some cases with a reduced disclosure obligation. A “foreign reporting company” is defined as an entity that is formed under the law of a foreign country and has registered to do business in any U.S. state.

A foreign reporting company that has not filed an initial BOIR now has a filing deadline of April 20, 2025. A foreign company that becomes a foreign reporting company in the future will have a filing deadline 30 days after being notified that it is officially registered to do business in a U.S. state. However, because the requirement to disclose the personal information of U.S. citizens and residents has been eliminated, the information to be disclosed by a foreign reporting company will be limited to company information and the personal information of foreign beneficial owners.

Should you have any questions about the Corporate Transparency Act, contact Attorney Tony Delyani at tony.delyani@mclane.com or (603) 334-6935.