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What is Corporate Transparency Act (CTA)?

2021 federal law requiring beneficial ownership disclosure to FinCEN via BOI reports. Upheld as constitutional in Dec 2025, but U.S.-formed companies are exempt from filing under the March 2025 interim rule (as of May 2026, interim and subject to change).

Also known as: CTA, Corporate Transparency Act

The Corporate Transparency Act (CTA) is a 2021 U.S. federal law that requires many companies to disclose their beneficial owners to FinCEN through a BOI report. Its goal is to make it harder to use anonymous shell companies for money laundering and fraud.

Statute vs. rule

  • The CTA is the law on the books (enacted 2021)
  • The BOI report is the filing mechanism the law calls for
  • FinCEN writes the rules defining who must file and when

Understanding that split explains why the requirement can flip while the statute remains.

Timeline (short)

When What happened
Jan 2024 BOI reporting goes live for covered companies
2024–early 2025 Court injunctions pause enforcement
Mar 2025 FinCEN interim final rule removes U.S.-formed entities from reporting
Dec 2025 11th Circuit upholds CTA constitutionality

Current status (May 2026)

The statute is alive; the U.S. filing requirement is paused. FinCEN's March 2025 interim final rule limits "reporting companies" to foreign-formed entities registering in the U.S.

As of May 2026, this is an interim rule, not finalized, and subject to change — a future final rule could reopen domestic filing.

Why it matters for privacy

When BOI reporting applies to U.S. companies, state-level anonymity is only half the picture. When it does not, WY/NM/DE public-record privacy regains its full value — without making you invisible to banks or the IRS.

Key takeaway

Track the CTA separately from day-to-day formation privacy. Full dated explainer: BOI reporting hub.

Source: Federal Register 2025-05199

Related Terms

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