Corporate Transparency Act Update: Exemption for Domestic Entities and New Requirements for Foreign Reporting Companies

ALBANY, NY | On March 21, 2025, FinCEN issued an interim final rule on the Corporate Transparency Act (CTA). As of March 26, 2025, all entities created in the US—including those known as “domestic reporting companies”—and their beneficial owners are exempt from the beneficial ownership information (BOI) reporting requirement imposed by the CTA.

Key Changes to Reporting Requirements for Foreign Companies

At this time, the Corporate Transparency Act only requires entities defined as “foreign reporting companies” to report BOI to FinCEN. The deadline for these entities is April 25, 2025. Additionally, foreign reporting companies are exempt from reporting the BOI of US persons who are beneficial owners of foreign reporting companies. Likewise, US beneficial owners are not obligated to report their BOI for foreign companies in which they hold an interest. This rule does not exempt US persons who are company applicants for foreign reporting companies.

A final rule is expected later this year. In the meantime, the interim final rule will be in effect and foreign reporting companies should prepare to comply.

For more information, visit: https://www.fincen.gov/boi

New York Companies, Be Aware: Separate Filing Requirement Under NY-LLCTA

The New York LLC Transparency Act (NYTA), effective January 1, 2026, requires LLCs formed or authorized to do business in New York to file a Beneficial Ownership Information Report. Existing LLCs must file by January 1, 2027, while new LLCs have 30 days to comply. Exempt LLCs must file an attestation and are subject to annual reporting. Noncompliance could lead to daily fines or potential dissolution after two years. Unlike the federal CTA, the NYTA is not subject to suspensions, so it’s important to understand the key differences and ensure compliance.

Written by: Shalini Natesan, Esq. & Jordan Porter, Law Clerk

The Towne Law Firm’s business law team provides advice and counsel to both publicly and privately held companies. We serve a wide range of industries, from small, closely held businesses to large entities with hundreds of employees and annual revenues in the hundreds of millions. Our team has the experience to address the various issues that arise in business formation, ownership, and operations.