BOI current status for foreign companies

TL;DR: Foreign-formed companies are the remaining CTA risk area. The owner being non-U.S. is not what matters; the company's formation jurisdiction and U.S. registration do.

Who is still in scope?

A company is potentially in scope if it was formed under foreign law and registered to do business in a U.S. state or tribal jurisdiction by filing with a secretary of state or similar office. A U.S.-formed LLC owned by a non-resident is not a foreign reporting company for this rule.

What are the current deadlines?

For foreign reporting companies registered before March 26, 2025, FinCEN's interim final rule set an April 25, 2025 initial-report deadline. For a foreign reporting company registered on or after March 26, 2025, the initial BOI report is due 30 calendar days after receiving notice that the registration is effective.

What changed before and after the interim final rule?

Before March 26, 2025: both domestic reporting companies and foreign reporting companies were generally subject to BOI unless exempt. After March 26, 2025: domestic U.S.-created companies and their beneficial owners are exempt; foreign reporting companies report only non-U.S. beneficial owners if no CTA exemption applies.

Primary sources

Last verified: June 26, 2026

• FinCEN news release, March 21, 2025
• FinCEN interim final rule Q&A
• Federal Register interim final rule, March 26, 2025

Where does this fit in Lanzamo?

This page is part of the Formation rule change log and complements the broader BOI guide for non-residents.

Is this legal or tax advice?

非法律/税务/移民建议，以官方为准。