- The Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued an interim final rule exempting all entities created in the United States – including those previously known as “domestic reporting companies” – and their beneficial owners from the requirement to report Beneficial Ownership Information (“BOI)”.
- Foreign entities that meet the new definition of a “reporting company” and do not qualify for an exemption from the reporting requirements must report their BOI to FinCEN under new deadlines, detailed in the interim final rule. Pursuant to the interim final rule, these foreign entities will not be required to report any U.S. persons as beneficial owners, and U.S. persons will not be required to report BOI with respect to any such entity for which they are a beneficial owner.
- FinCEN is accepting comments on the interim final rule and intends to finalize the rule this year.
What you should do
- Contact us if you have questions
- If your entity was created in a state other than Florida, please check that state’s requirements to ensure compliance and avoid possible penalties
- If your entity was created in a country other than the U.S., check the FinCEN requirements to ensure compliance and avoid possible penalties
- Continue to track reporting requirements at https://fincen.gov/boi
- FinCEN has learned of fraudulent attempts to solicit information subject to reporting requirements under the Corporate Transparency Act. Be on the lookout for fraudulent correspondence. If you receive correspondence: (i) verify the sender; and (ii) do not give personal information to anyone unless you trust the other party and the method by which you are delivering the information. FinCEN issued an Alert on December 18, 2024, to raise awareness of fraud schemes. Learn more about these schemes and where to report them https://fincen.gov/sites/default/files/2024-12/Alert-FinCEN-Scams-FINAL508.pdf.
This communication provides only limited and general information about the Corporate Transparency Act (“CTA”), does not constitute legal advice, does not create an attorney-client relationship between Milgrim Law Group and you or your company, or create any duties on behalf of Milgrim Law Group to provide advice with respect to the CTA. Milgrim Law Group provides advice related to CTA compliance and other matters only to current clients – and only when we expressly agree to do so in writing. Milgrim Law Group is not responsible for updating you or your company about developments regarding the CTA.
