April 25 Deadline for Select "Registered" Foreign Companies

• FinCEN revised the definition of “reporting company” to mean only those entities that are formed under the law of a foreign country and that have registered to do business in any U.S. State or Tribal jurisdiction by the filing of a document with a secretary of state or similar office (formerly known as “foreign reporting companies”).
• All entities created in the United States — including those previously known as “domestic reporting companies” — and their beneficial owners are now exempt from the requirement to report beneficial ownership information (BOI) to FinCEN.
• Foreign entities which are not registered with a U.S. state or tribal jurisdiction are not required to file a BOI report.

Key Deadline to Consider for Foreign Entities Which are Registered with a Secretary of State - April 25, 2025: 

All entities which are both formed under the law of a foreign country AND which have registered to do business with a U.S. secretary of state or similar office have until April 25, 2025, to submit their BOI report. 

Going forward, foreign entities that register to do business with a secretary of state or similar office have 30 days to file an initial BOI report after their registration is effective.

If you have any questions, please contact your local Rödl & Partner representative.​​

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