If you hold your apartments through an LLC, you may remember the federal Corporate Transparency Act and its beneficial ownership information (BOI) reports. The reporting duty for U.S. companies is gone, and as of this summer that change is permanent.
What changed
On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) announced an interim final rule, and it was published on March 26, 2025. It removed the reporting requirement for companies created in the United States and for their U.S. beneficial owners. FinCEN's BOI page states that U.S. companies are exempt and are no longer required to file BOI reports, and that U.S. persons do not need to provide BOI to a reporting company.
On August 11, 2026, FinCEN issued a final rule that makes those exemptions permanent. The final rule took effect on August 14, 2026.
Who this affects
Owners of Nevada LLCs, corporations and limited partnerships that were formed in the United States. Under the interim rule, only certain foreign entities that registered to do business in the United States and do not qualify for another exemption remained subject to reporting. If you own through a company formed outside the United States, read FinCEN's page directly, because this summary does not cover that situation.
Effective date
The exemption has applied since the interim rule was published on March 26, 2025. The final rule became effective on August 14, 2026.
What owners should do
- Do not file a new BOI report for a U.S. entity. FinCEN says none is required.
- Keep your own ownership records current anyway. Lenders, insurers and title companies may still ask who owns an entity, and clean records save time at a refinance or sale.
- If you already filed a report, you do not need to take further action based on this rule. If you have a question about a specific filing, ask your attorney.
- Check FinCEN's BOI page before relying on this post, since federal rules can change again.
This is a summary, not legal advice. Talk to your attorney about your own entities.