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Filing Deadlines Beneficial Owner

Orrick, Herrington & Sutcliffe LLP

The Economic Crime and Corporate Transparency Act 2023: Identity Verification

Identity Verification (“IDV”) is a new process requiring individuals that run, own or control UK companies or limited liability partnerships (“LLPs”) to prove their identity to Companies House. IDV registration is voluntary...more

A&O Shearman

The Register of Overseas Entities – What the Real Estate Industry Needs to Know (Updated)

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Any overseas entity acquiring a Qualifying Estate must register on the Register of Overseas Entities (ROE). The ROE opened for registrations on August 1, 2022. Since September 5, 2022, an overseas entity that is not...more

Conyers

BVI Corporate Review – Q2 2025

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As outlined in our Q1 2025 review, important amendments to BVI company law came into effect as of 2 January 2025, including a requirement to file beneficial ownership information through the VIRRGIN system maintained by the...more

Adams & Reese

FinCEN Rule Targets All-Cash Residential Real Estate Deals Involving Entities & Trusts

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A new nationwide anti-money laundering rule introduces mandatory reporting to the U.S. Department of Treasury’s FinCEN (Financial Crimes Enforcement Network) for specific all-cash residential real estate transactions...more

Fenwick & West LLP

SEC's Corp. Fin. Amends CDIs Related to Regulation 13D-G Reporting Rules

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On July 11, the SEC’s Division of Corporation Finance amended 18 Compliance and Disclosure Interpretations relating to Regulation 13D-G, which pertains to beneficial ownership reporting rules.  These amendments bring the...more

Winstead PC

SEC Adopts Amendments to Beneficial Ownership Reporting Rules for Schedules 13D and 13G

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In 2023, the Securities and Exchange Commission (the “SEC”) adopted amendments and issued guidance to modernize the rules governing beneficial ownership reporting under Sections 13(d) and 13(g) of the Securities Exchange Act...more

Carey Olsen

New filing requirements for BVI companies - frequently asked questions

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As a result of the BVI Business Companies (Amendment) Act, 2024 and the BVI Business Companies and Limited Partnership (Beneficial Ownership) Regulations, 2024, all companies incorporated or registered in the British Virgin...more

ArentFox Schiff

Beneficial Owner Disclosure Under the New York LLC Transparency Act

ArentFox Schiff on

After a rollercoaster of activity related to the federal Corporate Transparency Act (CTA), the US Treasury Department (Treasury) announced on March 2 that it will not enforce any penalties or fines associated with beneficial...more

Troutman Pepper Locke

Practical Implications of the Interim Final Rule for BOI Reporting Under the CTA

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As we previously discussed, the Financial Crimes Enforcement Network (FinCEN) published an interim final rule (IFR) on March 26 that narrowed the beneficial ownership information (BOI) reporting requirements under the...more

Pillsbury Winthrop Shaw Pittman LLP

CTA Deadline Approaching for Foreign Reporting Companies

The Corporate Transparency Act (CTA) was adopted by Congress in January 2021 and became effective on January 1, 2024. Under the CTA and the initial regulations implementing it, “reporting companies” (corporations, LLCs,...more

Greenberg Glusker LLP

Out with a Whimper: FinCEN Issues Interim Final Rule on Corporate Transparency Act, Narrows BOI Reporting Requirements

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On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) announced an interim final rule, which was officially published in the Federal Register on March 26, 2025, removing the requirement for U.S. companies and...more

Snell & Wilmer

The (Almost) End of the Corporate Transparency Act

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In a whirlwind attempt to follow the roller coaster actions in the courts, the U.S. Congress, and FinCEN’s administrative efforts, Snell & Wilmer has worked to keep clients updated with the drama-filled developments of the...more

Husch Blackwell LLP

FinCEN Removes Beneficial Ownership Reporting Requirements for U.S. Companies and U.S. Persons Under the CTA

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On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) issued an interim final rule (IFR) removing the requirement for U.S. domestic reporting companies and U.S. persons to report Beneficial Ownership...more

Miller Canfield

UPDATED: FinCEN’s New Interim Final Rule (1) Exempts Domestic Companies from Corporate Transparency Act Reporting and (2) Sets New...

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On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of Treasury (Treasury) issued a new interim final rule (new IFR) significantly limiting the scope of reporting required under the...more

PilieroMazza PLLC

Corporate Transparency Act, Part 10: Interim Final Rule, U.S. Companies and U.S. Persons Exempt From Reporting

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On March 26, 2025, FinCEN issued an interim final rule and request for comments, removing the requirement under the Corporate Transparency Act (CTA) for both U.S. companies and U.S. persons to report beneficial ownership...more

Patterson Belknap Webb & Tyler LLP

FinCEN Issues Interim Final Rule Under the Corporate Transparency Act

On March 21, 2025, FinCEN released an interim final rule (the “Interim Final Rule”) that exempts domestic reporting companies and U.S. persons from being required to report beneficial ownership and company applicant...more

Winstead PC

Corporate Transparency Act Update: U.S. Companies No Longer Subject to Reporting Obligations

Winstead PC on

As promised, FinCEN has adopted its interim final rule and narrowed the filing requirements for Beneficial Ownership Information (“BOI”) reporting under the Corporate Transparency Act (“CTA”). This rule exempts U.S. entities...more

Cadwalader, Wickersham & Taft LLP

New Regulatory Priorities Spring Into Focus, April 2025 - FinCEN Releases New Corporate Transparency Act Rule Exempting U.S....

On March 21st 2025, the Financial Crimes Enforcement Network (“FinCEN”) released a new interim final rule that exempts U.S. entities and U.S. beneficial owners from the reporting requirements of the Corporate Transparency Act...more

Lowndes

On Again, Off Again: FinCEN's New Interim Final Rule on the Corporate Transparency Act – U.S. Entities and Citizens Exempt from...

Lowndes on

Anyone who has followed the on-again, off-again history of the Corporate Transparency Act’s (CTA) Beneficial Owner Information (BOI) reporting requirements will not be surprised that, effective March 26, the Financial Crimes...more

Holland & Knight LLP

Interim Final Rule Clarifies Tribal Entities Not Subject to Corporate Transparency Act

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The Financial Crimes Enforcement Network (FinCEN), a unit of the U.S. Department of the Treasury charged with administering the Corporate Transparency Act (CTA), issued an interim final rule on March 21, 2025, that exempts...more

Lathrop GPM

U.S. Entities and U.S. Persons Are No Longer Required to Make CTA Filings under CTA Interim Final Rule

Lathrop GPM on

Consistent with our expectations as reported in our last Legal Update dated March 4, 2025, on March 26, 2025, the United States Department of the Treasury Financial Crimes Enforcement Network (“FinCEN”) published an interim...more

ArentFox Schiff

CTA Drastically Pared Back

ArentFox Schiff on

As promised by the US Department of Treasury in early March, the Financial Crimes Enforcement Network (FinCEN) issued an interim final rule removing the requirement for US companies, their beneficial owners, and US persons to...more

Eversheds Sutherland (US) LLP

Tax Bytes: Week of March 31, 2025

Upcoming Eversheds Sutherland event - Join us for a two-day controversy seminar in Washington, DC covering legislative reviews, state, federal, and international tax updates, LB&I hot topics, appeals, transfer pricing,...more

Fenwick & West LLP

The Corporate Transparency Act: FinCEN Removes Reporting Reqs for US Companies and Persons, Sets New Deadlines for Foreign...

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In a press release issued on March 21, 2025, FinCEN issued an interim final rule (IFR) revising the definition of “reporting company” to mean only those entities formed under the laws of a foreign country that have registered...more

Stoel Rives LLP

Corporate Transparency Act – New Interim Final Rule

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The U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued an interim final rule with respect to the Corporation Transparency Act (the “CTA”), exempting entities formed in the United States from the...more

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