News & Analysis as of

Foreign Entities Filing Requirements

Miller Canfield

UPDATED: FinCEN’s New Interim Final Rule (1) Exempts Domestic Companies from Corporate Transparency Act Reporting and (2) Sets New...

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On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of Treasury (Treasury) issued a new interim final rule (new IFR) significantly limiting the scope of reporting required under the...more

PilieroMazza PLLC

Corporate Transparency Act, Part 10: Interim Final Rule, U.S. Companies and U.S. Persons Exempt From Reporting

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On March 26, 2025, FinCEN issued an interim final rule and request for comments, removing the requirement under the Corporate Transparency Act (CTA) for both U.S. companies and U.S. persons to report beneficial ownership...more

Lowndes

On Again, Off Again: FinCEN's New Interim Final Rule on the Corporate Transparency Act – U.S. Entities and Citizens Exempt from...

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Anyone who has followed the on-again, off-again history of the Corporate Transparency Act’s (CTA) Beneficial Owner Information (BOI) reporting requirements will not be surprised that, effective March 26, the Financial Crimes...more

Bodman

U.S. Companies and Business Owners Exempted from CTA Reporting Requirements

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The Financial Crimes Enforcement Network (“FinCEN”) has issued an interim final rule that would exempt U.S. companies and U.S. persons from reporting their beneficial ownership information (“BOI”) as part of the Corporate...more

Vicente LLP

Corporate Transparency Act, We Hardly Knew Ye: What the Interim Final Rule Means for U.S. Businesses

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The Corporate Transparency Act (CTA) has undergone a significant shift. The FinCEN recently issued a new Interim Final Rule (IFR), dramatically narrowing the law's reach. As a result, most U.S. companies no longer have...more

Winthrop & Weinstine, P.A.

FinCEN Exempts U.S. Companies from CTA Reporting — But Legal Uncertainty Remains

Key Development: FinCEN Limits CTA Reporting to Foreign Entities — For Now On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) issued an interim final rule (IFR) that significantly narrows the reporting...more

Mayer Brown

End of the Road: FinCEN Adopts Interim Final Rule Virtually Eliminating CTA Filing Requirements

Mayer Brown on

On March 21, 2025, the US Financial Crimes Enforcement Network (“FinCEN”) issued an interim final rule (the “IFR”) that exempts all domestic entities from beneficial ownership information reporting requirements under the...more

Nelson Mullins Riley & Scarborough LLP

FinCEN Drops BOI Reporting for U.S. Companies, Keeps Rules for Foreign Entities

On March 21, FinCEN released a statement that echoes the U.S. Department of the Treasury’s announcement on March 2, removing all beneficial ownership reporting obligations for U.S. companies and persons under the Corporate...more

Sullivan & Worcester

Breaking: FinCEN Removes BOI Reporting Requirements for U.S. Companies and U.S. Persons

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The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced, on March 21, 2025, that it issued an interim final rule that removes the requirements for U.S. companies and U.S. persons to...more

McNees Wallace & Nurick LLC

Closing Call for the Corporate Transparency Act: FinCEN Removes Reporting Requirements for Domestic Business Entities

After almost fifteen months of legal challenges, conflicting court rulings, changing guidance from the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN), and a general air of uncertainty, it appears...more

Cozen O'Connor

FinCEN Exempts US Entities and Persons from CTA

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On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) adopted an interim final rule (Rule) exempting U.S. companies previously subject to the reporting requirements under the Corporate Transparency Act (CTA)...more

Vinson & Elkins LLP

FinCEN Issues Interim Final Rule – BOI Reporting Obligations Narrowed to Foreign Reporting Companies and New Deadlines Issued

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As we previously discussed and in alignment with the U.S. Treasury Department’s previous announcement, on March 21, 2025, the Financial Crimes Enforcement Network (“FinCEN”) issued an interim final rule that dramatically...more

Moritt Hock & Hamroff LLP

Important Update On The Corporate Transparency Act: FinCEN Issues Interim Final Rule

On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) issued a new interim final rule that removes the beneficial ownership information (BOI) reporting requirements for U.S. companies and U.S. persons. The rule...more

Verrill

It’s Official: All U.S. Entities Excluded from Filing Obligations Under the Corporate Transparency Act

Verrill on

On March 21, 2025, FinCEN published an “interim final rule” (IFR) that makes sweeping changes in the reach of the Corporate Transparency Act. The IFR is immediately effective and eliminates all BOI report obligations for all...more

Hinshaw & Culbertson LLP

FinCEN Confirms U.S. Companies and U.S. Persons are Exempt from CTA Compliance

In a significant development, the Financial Crimes Enforcement Network (FinCEN) recently issued an interim final rule (the IFR) that dramatically changes who is subject to the Corporate Transparency Act (CTA) and its...more

Lathrop GPM

Treasury Department Says It Will Not Enforce CTA Reporting Obligations for Domestic Entities. Additional Changes in Store.

Lathrop GPM on

On March 2, 2025, the U.S. Treasury Department announced suspension of the March 21, 2025 deadline for filing under the Corporate Transparency Act (CTA) for any domestic companies or U.S. citizens. The Department indicated...more

Torres Trade Law, PLLC

The Corporate Transparency Act: Treasury’s New Back Door for Finding CFIUS Non-Notified Transactions

Torres Trade Law, PLLC on

Much has been written about the Corporate Transparency Act (“CTA”), which was enacted on January 1, 2021, and went into effect on January 1, 2024. Briefly, the CTA requires “reporting companies” to disclose beneficial...more

BakerHostetler

D.C. Court of Appeals Strengthens IRS’ Ability to Collect Penalties for Not Reporting Foreign Company Ownership

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On April 3, 2023, the United States Tax Court issued its opinion in Farhy v. Commissioner of Internal Revenue, which upset long-standing views on how the IRS may assess and collect penalties for failure to file certain tax...more

King & Spalding

Bank Failures May Raise CFIUS Issues

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Companies need to be aware of filing requirements before taking foreign money - On March 14, 2023, after a week of three bank failures that marked the largest such crisis since 2008, policymakers continued seeking private...more

Holland & Knight LLP

Avoiding Pitfalls When Exporting Aircraft from the United States (Updated September 25, 2022)

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Update: This Holland & Knight alert has been updated on Sept. 25, 2022, with additional information. In plain English, anytime an aircraft departs the United States, this is an "export" and will fall in one of two "buckets":...more

Goodwin

An Overview of the Latest Human Genetic Resources Regime in China

Goodwin on

On July 1, 2019, the Administrative Regulations on Human Genetic Resources (人类遗传资源管理条例) (the “Regulations”) issued by the State Council of the People’s Republic of China (the “PRC”) came into effect. On October 17, 2020, the...more

Hutchison PLLC

Another Form to File: BE-13 Survey on Foreign Direct Investment

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In a transaction involving an acquisition, formation or investment in a U.S. business by a foreign entity, there are a variety of legal, business, financial and operational matters to carefully consider, and ultimately, on...more

Foley Hoag LLP

BE-10 Benchmark Survey of U.S. Direct Investment Abroad – Filing Requirement

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The U.S. Bureau of Economic Analysis (BEA) has announced it is once again time for the BEA’s BE-10 Benchmark Survey of U.S. Direct Investment Abroad. The BEA is an agency of the United States Department of Commerce and...more

Proskauer - Not for Profit/Exempt...

TIC Form SHC Deadline Approaching to Report U.S. Ownership of Foreign Securities

The U.S. Department of the Treasury recently released a revised Form SHC (with corresponding instructions), which is part of the Treasury International Capital (TIC) data reporting system. Form SHC is the mandatory five-year...more

Proskauer Rose LLP

TIC Form SHC Deadline Approaching to Report U.S. Ownership of Foreign Securities

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Form Deadline Is March 3, 2017 - Introduction - The U.S. Department of the Treasury recently released a revised Form SHC (with corresponding instructions), which is part of the Treasury International Capital (TIC)...more

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