Beneficial Ownership Reporting for U.S. Companies
August 15, 2026
Beneficial Ownership Reporting for U.S. Companies Is Officially Over: What Tax Professionals Should Know
By Mary Beth Lougen, EA, U.S. Tax Court Practitioner, COO – Expat Tax Tools
For the past several years, beneficial ownership information reporting under the Corporate Transparency Act has been a moving target.
Tax professionals and business owners have dealt with new filing requirements, changing deadlines, court challenges, and eventually a significant rollback of the rules. Now we finally have something much more definitive.
On August 14, 2026, the Financial Crimes Enforcement Network (FinCEN) issued a final rule that permanently removes beneficial ownership information (BOI) reporting requirements for U.S. companies and U.S. persons under the Corporate Transparency Act. For practitioners who spent considerable time learning the BOI rules and helping clients determine whether they needed to file, this is an important development.
The 2025 Change Is Now Permanent
The biggest point to understand is that this didn’t happen overnight. In March 2025, FinCEN issued an interim final rule that dramatically narrowed the
Corporate Transparency Act’s reporting requirements. U.S.-created entities and U.S. persons were generally removed from the BOI reporting regime.
The August 2026 final rule makes those exemptions permanent. In practical terms, domestic U.S. companies are no longer required to file BOI reports
with FinCEN.
That’s welcome clarity after several years in which practitioners had to keep up with frequent changes to the rules and advise clients accordingly.
What Happens to Information That Was Already Filed?
This may be one of the first questions clients ask. Many business owners complied with the original rules and submitted beneficial
ownership information before the reporting requirements changed.
FinCEN has now announced that it will delete previously reported information about individuals it reasonably believes are U.S. persons from its BOI database. This includes information associated with U.S. persons who were reported as beneficial owners or company applicants, as well as information provided by U.S. persons who obtained FinCEN identifiers.
FinCEN also says that U.S. persons who previously obtained FinCEN IDs will not be required to update or correct the information they originally submitted to obtain those IDs.
That is an important detail for practitioners who may still have clients asking whether they need to maintain or update previously submitted information.
BOI Reporting Hasn’t Disappeared Completely
This is where I think tax professionals need to be careful. It would be easy for clients to hear that “BOI reporting is over” and assume that the
Corporate Transparency Act no longer applies to anyone. That’s not quite correct.
Under the final rule, certain foreign entities registered to do business in the United States remain subject to BOI reporting requirements. Those reporting companies are still required to report beneficial ownership information for foreign individuals who meet the applicable reporting requirements.
At the same time, the final rule eliminates certain reporting involving U.S. persons. For example, foreign reporting companies no longer have to report U.S. person company applicants. There are also specific changes affecting foreign pooled investment vehicles registered in the United States.
So while BOI reporting is effectively over for U.S. companies and U.S. persons, practitioners working with international structures should not simply remove BOI from their compliance checklists altogether.
What Should Tax Professionals Do Now?
For most firms, I think the immediate task is fairly straightforward: update your procedures and client communications.
If your firm incorporated BOI reporting into new-client onboarding, entity-formation checklists, annual compliance reminders, engagement letters, or client portals, those materials should be reviewed.
Practitioners should also be prepared for questions from clients who previously filed reports. The message to most U.S. business owners is now considerably simpler: the federal BOI reporting requirement that generated so much attention over the past few years no longer applies to domestic U.S. companies.
But for practitioners with international clients, there is still another question to ask: Is there a foreign entity registered to do business in the United States?
If the answer is yes, the analysis may not be finished.
A Welcome Bit of Certainty
Tax professionals have had to spend an extraordinary amount of time over the past several years keeping track of the Corporate Transparency Act.
We learned the rules. We identified reporting companies. We educated clients about beneficial owners and company applicants. Then we followed court decisions, deadline changes and regulatory revisions that repeatedly changed what those clients were required to do.
The final rule gives us something we haven’t had much of with BOI reporting: certainty. For the overwhelming majority of U.S. businesses, BOI reporting to FinCEN is now a closed chapter.
For international tax professionals, however, it’s worth remembering the footnote: certain foreign entities registered to do business in the United States remain within the reporting regime. And, as is so often the case in international tax and compliance, that footnote can matter.
About the Author
Mary Beth Lougen, EA, U.S. Tax Court Practitioner, NTPI Fellow, is Chief Operating Officer of Expat Tax Tools. She has more than 35 years of experience in U.S. international taxation and has assisted thousands of taxpayers and tax professionals with complex cross-border compliance issues. Mary Beth is a frequent speaker on international tax topics and has taught continuing education programs for CPAs, Enrolled Agents, and tax practitioners throughout the United States and abroad.
Expat Tax Tools develops specialized software for international tax professionals, including the Form 8621 Calculator and Section 962 Election Assistant and the Global Gains Pro for capital gains.