Interim Final Rule Issued by FinCEN Removes Corporate Transparency Act Reporting Requirements for U.S. Companies and U.S. Persons
As we previously wrote, the Treasury Department issued a press release on March 2 that states that it will not enforce any penalties or fines against U.S. citizens or domestic reporting companies, or their beneficial owners associated with the beneficial ownership information (BOI) reporting rule under the Corporate Transparency Act. As promised in the Treasury Department’s press release, the Financial Crimes Enforcement Network (FinCEN) recently issued an interim final rule effective March 26, 2025. The interim final rule removes the requirement for U.S. companies and U.S. persons to report BOI to FinCEN under the Corporate Transparency Act by narrowing the definition of “reporting company” to include only those entities that are formed under the law of a foreign country and that have registered to do business in any U.S. State or Tribal jurisdiction. However, the interim final rule does not change the existing requirement for foreign reporting companies to file BOI reports but does provide extended deadlines for foreign reporting companies to file initial BOI reports, and to update or correct previously filed BOI reports. The public may provide written comments regarding this interim final rule on or before May 27, 2025.
If you have questions relating to the Federal Corporate Transparency Act or the New York State LLC Transparency Act, contact our business attorneys, Michael F. McConville at mmcconville@mccmlaw.com or 585-512-3520; Letty Laskowski at llaskowski@mccmlaw.com or 585-512-3538; Amy L. Varel at avarel@mccmlaw.com or 585-512-3506.
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About MCCM
McConville Considine Cooman & Morin, P.C. is a full-service law firm based in Rochester, New York, providing high-quality legal services to businesses and individuals since 1979. With over a dozen attorneys and a full paralegal support staff, the firm is well-positioned to right-size services tailored to each client. We are large enough to provide expertise in a broad range of practice areas, yet small enough to devote prompt, personal attention to our clients.
We represent a diverse range of clients located throughout New York State and New England. They include individuals, numerous manufacturing and service industry businesses, local governments, and health care professionals, provider groups, facilities and associations. We also serve as local counsel to out-of-state clients and their attorneys who have litigation pending in Western New York courts. For more information, please contact us at 585.546.2500.