The Financial Crimes Enforcement Network (FinCEN) announced an Interim Final Rule on March 21, 2025, that it will not require US companies and persons to report beneficial ownership information (BOI) pursuant to the Corporate Transparency Act (CTA).
FinCEN revised the definition of “reporting company” to mean only entities formed under the law of a foreign country and that have registered to do business in the US by filing with a secretary of state or similar office (formerly known as “foreign reporting companies”). The Interim Final Rule also specifically exempts entities previously known as “domestic reporting companies” from BOI reporting requirements.
This means that all entities created in the United States and their beneficial owners are exempt from reporting BOI to FinCEN. Foreign entities that meet the new definition of a “reporting company” and do not qualify for an exemption must report their BOI to FinCEN under new deadlines that will be determined later. However, these foreign entities will not be required to report any US persons as beneficial owners, and US persons will not be required to report BOI with respect to any entity for which they are a beneficial owner.
The Interim Final Rule became effective immediately. While the comment period could lead to another change or reversal of requirements, it appears unlikely under the current administration. TKE will provide updates on any changes on this site should they occur.
Our co-founder, partner and friend, Myron, will be fondly and forever remembered for his love of the practice, his enthusiasm for working each day of his 59-year long career, his intellect, and for his dedication to his clients. TKE is honored to carry on the law practice with the same quality and character Myron embraced.
Misty has many years of experience in documentation, process improvement, and benefits administration. As a native Kansan, she has two very important mantras – to the stars through difficulties “ad aspera per aspera” and Rock, Chalk, Jayhawk.
Leonard concentrates his practice in corporate and business matters, commercial real estate, business litigation, contracts, business transactions, mergers and acquisitions, and tax controversies. Leonard is licensed to practice law in both Illinois and Wisconsin.
Leonard received his J.D. from the University Of San Diego School Of Law, received his B.S. from Northern Illinois University in 1979 with a degree in accounting, and practiced in public accounting before attending law school. Leonard is admitted to practice before the United States Tax Court and the United States District Court for the Northern District of Illinois.
Leonard enjoys music, restoring stereo equipment and playing vintage guitars.
Cyndi concentrates her practice in Federal taxation: controversy (audits and appeals), advocacy, and tax preparation (individuals, trusts, estates, gifts, private foundations); estate planning and trust/probate administration; and business transactions.
Cyndi holds a J.D. and an LL.M in taxation (with honors) from the University of Illinois-Chicago School of Law and a B.S.B.A. degree in business management from Roosevelt University. She taught tax accounting for many years as an adjunct professor of law in LL.M. and MST programs and has served on the IRS Advisory Council (Small Business/Self-Employed Committee).
When not assisting clients with their tax and business matters, Cyndi enjoys traveling and spending time with family.
Jennifer focuses her practice on counseling individuals, entrepreneurs and business leaders to prevent, navigate and resolve legal issues and disputes. Clients rely on Jennifer for her assistance and advice on business formations, day-to-day operational matters, preparation, review and negotiation of contracts, and every stage and situation encountered with businesses and their owners. She is a trusted advisor to the firm’s clients and frequently acts as house counsel for many of the closely-held businesses she represents.
Jennifer received her J.D. cum laude at Syracuse University’s College of Law and received her B.A. in political science at Northwestern University. She is a member of the Illinois State Bar Association, Trusted Advisors Council, Empowered Professional Women Networking Group (EPWNG), and North Shore Law.
Jennifer enjoys time with her family, travel, and a nice red wine.
Gavin concentrates his practice in the areas of Federal taxation (S-Corp, partnerships) and estate planning.
In addition to his undergraduate degrees in Finance and Marketing, Gavin received his J.D. and LL.M. in Taxation from the University of Illinois-Chicago School of Law.
Gavin treasures his family values and traditions and is passing them on to his two children. In his spare time, he enjoys carpentry work and creating living spaces.
Misty has many years of experience in documentation, process improvement, and benefits administration. As a native Kansan, she has two very important mantras – to the stars through difficulties “ad aspera per aspera” and Rock, Chalk, Jayhawk.
