Exemption for Domestic Entities from Corporate Transparency Act Reporting Requirements

On March 26, 2025, the U.S. Treasury Department issued an important update regarding the Corporate Transparency Act (CTA). Effective immediately, all entities created in the United States, including those previously classified as “domestic reporting companies,” are no longer required to report beneficial ownership information (BOI) to the Financial Crimes Enforcement Network (FinCEN). This exemption applies to both new and existing domestic companies.

This decision marks a shift in the implementation of the CTA, with the focus now on foreign companies. These foreign entities are still obligated to report their beneficial ownership information to FinCEN but have been granted an additional 30-day extension. The new deadline for foreign companies to comply with the CTA’s reporting requirements is April 25, 2025.

Under the CTA, a foreign entity is defined as any company or legal entity that is formed or registered outside the United States but is doing business in the United States.  

Foreign companies must report their beneficial owners to FinCEN if they are registered to do business in the United States or own property within the country. These entities are subject to the CTA’s reporting requirements unless they qualify for an exemption.

This update signals a shift in enforcement priorities, with the Treasury focusing on foreign companies while domestic entities are exempt from compliance.