A Final Chapter in the Corporate Transparency Act Saga

For those of you who have been following our updates on the Corporate Transparency Act and BOIR reporting, or have otherwise been keeping an eye on this year and a half long saga, you know that there has been no small amount of confusion regarding the Act’s requirements, enforcement, and deadlines. We’ve posted several times about the Act over the past year as injunctions were placed and lifted, reporting deadlines were set and pushed back, and businesses were left in limbo. As of March however, it appears we may be seeing the final chapter of this story.

On March 26, 2025, the Financial Crimes Enforcement Network, which oversaw the implementation of the Act, issued an interim rule which significantly narrows the scope of the Act’s reporting requirements. Now, reporting obligations are effectively limited only to foreign reporting companies. Domestic entities such as trusts, corporations, and limited liability companies, on the other hand, are exempt, as are US persons even if they are beneficial owners of a foreign entity doing business in the United States. While a final rule is yet to be announced, it appears these exemptions are around to stay, bringing an end to much of the confusion surrounding the Act.