"Comprehensive Guide to Ownership Details for Writers: All Essential Information Explained"
As of April 25, 2025, only foreign entities registered to do business in the U.S. are required to file Beneficial Ownership Information (BOI) reports under the Corporate Transparency Act (CTA). U.S.-formed entities are exempt from BOI reporting as per the March 21, 2025 interim final rule by FinCEN.
Key Reporting Deadlines for Foreign Entities
- If the foreign entity became a reporting company (i.e., registered) before March 26, 2025, its initial BOI report was due no later than April 25, 2025.
- If the foreign entity became a reporting company on or after March 26, 2025, it must file its initial BOI report within 30 calendar days of receiving notice that its registration is effective.
BOI Reporting Requirements
The reports must include information about beneficial owners, which typically includes full legal name, date of birth, residential or business address, and a unique identifying number from a government-issued ID (e.g., passport or driver's license).
Information must be submitted directly to FinCEN through their BOI reporting portal, not through third-party software. Foreign entities must update their BOI reports within 30 days if there are any changes in ownership or company information.
Summary of the Updated Scope
| Entity Type | BOI Filing Requirement | Deadline | |------------------------------------|------------------------------------------------|---------------------------------------| | Foreign entity registered in U.S. | Required to file initial and update BOI reports | Initial: By April 25, 2025 if before 3/26/25; thereafter 30 days after notification of registration effectiveness | | Domestic U.S.-formed entity | Exempt from filing BOI reports (as of March 21, 2025) | N/A |
This reporting regime is part of anti-money laundering and transparency efforts focused on foreign companies doing business in the U.S.; domestic companies are currently exempt unless future FinCEN rule changes occur.
If you represent or manage a foreign reporting company registered in the U.S., be certain to meet these deadlines and submit accurate, updated beneficial ownership data directly to FinCEN’s system.
- Optional creation of a FinCEN ID can simplify the reporting process.
- To stay updated on changes in BOI reporting requirements, sign up for FinCEN updates via email or text by clicking here.
- No attorney or certified accountant is needed for BOI reporting.
- Foreign entities registered to do business in the U.S. must file Beneficial Ownership Information (BOI) reports under the Corporate Transparency Act (CTA), as these reports are a part of the anti-money laundering and transparency efforts focused on foreign companies conducting business in the United States.
- In addition to conducting business in the U.S., foreign entities are also engaged in finance, as they are required to provide financial information like full legal names, dates of birth, residential or business addresses, and unique identifying numbers from government-issued IDs for BOI reporting.
