As promised, the U.S. Treasury Department issued a final rule regarding the Corporate Transparency Act on August 11, 2026, replacing the interim rule issued in March of 2025. Pursuant to that final rule:
- Companies formed in the United States are not required to file Beneficial Ownership Information Reports (BOIRs) with the Financial Crimes Enforcement Network (FinCEN).
- FinCEN will delete all information previously reported by U.S. persons from the beneficial ownership information database.
- Only foreign companies which are registered to do business in the U.S. are required to file BOIRs, and those BOIRs are not required to include any information on U.S. persons.
As a result, the Corporate Transparency Act conclusively no longer applies to domestic companies or U.S. persons, and any beneficial owner information previously reported by domestic companies and U.S. persons who filed reports will be deleted.
If you have any questions, please contact Edmund G. Kauntz at [email protected] or Nathaniel D. Tucker at [email protected] or via telephone at 216-292-5807.
