FinCEN's final rule, announced August 11, 2026, permanently removes the Corporate Transparency Act reporting requirement for U.S. companies and U.S. persons. Foreign reporting companies still report for their foreign beneficial owners.
The Corporate Transparency Act required most small companies to file beneficial ownership information (BOI) reports with FinCEN. After a March 2025 interim rule exempted domestic companies, FinCEN announced on August 11, 2026 a final rule that permanently removes the requirement for U.S. companies and U.S. persons to report beneficial ownership information, and stated that it will delete the data those filers previously submitted.
Foreign entities that qualify as reporting companies, meaning companies formed under foreign law and registered to do business in a U.S. state, must still report beneficial ownership information for their foreign beneficial owners. The rule takes effect on publication in the Federal Register.
For Michigan LLCs and corporations this closes the question: there is no BOI report to file, update, or correct. Companies that received solicitations from third party filing services should treat them accordingly. Foreign owned structures should confirm which side of the line they fall on before assuming they are exempt.
Information here is general and is not advice for your situation. For advice about your situation, contact us.
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