Lisa and the Law

Mandatory deadline for nonexempt foreign reporting companies to file their initial BOIRs, but there is no requirement to report their beneficial owners that are U.S. persons.

Posted on April 23, 2025

April 25, 2025 is the deadline for nonexempt foreign reporting companies created before March 26, 2025, to file their initial BOIR (Beneficial Ownership Information Report). Beneficial owners of those foreign reporting companies that are U.S. persons do not need to be reported or provide their beneficial ownership information to the foreign reporting company. Any new nonexempt foreign reporting company created after March 26, 2025, has thirty (30) calendar days from the date of registration to file its initial BOIR. Changes to any existing BOIR for reporting companies subject to enforcement of the CTA must be made within thirty (30) calendar days of the change.

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