Final (Hopefully) Update: U.S. Companies and Individuals Exempt from BOI Reporting Requirements

We have great news - news that we hope will be the last to report to you on this topic.

After many months and many updates, our firm is happy to provide a final (hopefully) update regarding Beneficial Ownership Information Reports (BOIR): reporting is no longer required for U.S. companies and individuals.

After the Financial Crimes Enforcement Network (FinCEN) recently issued its interim final rule, it is clear that (1) U.S. companies and individuals are no longer required to file reports, and (2) U.S. individuals are not required to report BOI for foreign entities they own.

Effectively, this means that only certain foreign entities registered to do business in the U.S. will need to file BOIR, and only foreign beneficial owners of those nonexempt foreign entities will have to report.

In short, this eliminates nearly all reporting requirements.

This was done through what is called an "interim final rule." Procedurally, it is put out for a public comment period, and then finalized later with a final rule (maybe by year-end). There was also legislation introduced to formally repeal the law so that future administrations could not revive it by a change in the rules. That legislation is pending.

As always, if you have questions, please feel free to contact us today. We are here to help.

Disclaimer

This publication is for general information only. The information contained is not intended as formal legal advice. If you have any questions or need assistance, please contact your attorney at Curtis, Curtis & Brelinski, P.C.

Article by: Ethan J. Loch