The Corporate Transparency Act created BOI reporting for millions of US entities. The March 2025 interim final rule narrowed it to foreign reporting companies only. Here is who must report today and who is exempt.
By Alif Al Razi, Tax & Compliance Lead, Anonymousllc.co · Last updated 2026-05-21
Regulatory disclosure: This page reflects the March 21, 2025 FinCEN interim final rule (90 FR 13688). FinCEN may issue a revised final rule that changes domestic company obligations. Track current status at /boi/status-tracker/.
The Corporate Transparency Act (31 USC 5336) defines a reporting company as any corporation, LLC, or similar entity created by filing a document with a secretary of state or similar office, or formed under the law of a foreign country and registered to do business in any US state or tribal jurisdiction. The implementing rule at 31 CFR 1010.380 splits this into two categories:
Under the March 21, 2025 interim final rule (90 FR 13688), FinCEN exempted all domestic reporting companies from BOI filing requirements. Only foreign reporting companies remain obligated.
A common point of confusion: a US LLC owned by a non-US resident is a domestic reporting company, not a foreign reporting company. The classification depends on where the entity was formed, not who owns it. A Wyoming LLC owned by a UK citizen is a domestic reporting company because it was formed under Wyoming law. It is currently exempt from BOI reporting under the March 2025 rule.
Contrast this with a UK Ltd that registers to do business in Wyoming. That entity was formed under UK law and is a foreign reporting company. It must file BOI reports.
Even before the March 2025 domestic exemption, 31 CFR 1010.380(c)(2) listed 23 categories of entities exempt from BOI reporting. These include large operating companies (20+ full-time US employees, $5M+ gross receipts, US physical office), banks, credit unions, money services businesses, broker-dealers, SEC reporting issuers, insurance companies, state-licensed insurance producers, registered investment companies, venture capital fund advisers, public utilities, tax-exempt entities, and others. Most anonymous LLC holders do not qualify for any of the 23 because small private LLCs do not meet the thresholds. The domestic exemption is what covers them.
Full list of all 23 exemptions: BOI Exemptions - The 23 Categories Plus Domestic.
Yes. The March 2025 rule is an interim final rule, not a permanent final rule. FinCEN accepted public comments through June 2025 and may issue a revised rule that reinstates obligations for some or all domestic companies. Congressional action may also modify or repeal the CTA entirely. The litigation in NFIB v. Yellen and related cases remains relevant.
Track changes in real time at /boi/status-tracker/.
Anonymousllc.co files BOI reports for foreign reporting companies at a flat $150. If you are unsure whether your entity must report, reach out - we will tell you for free.