By Jessica S. Kaczinski and Ian T. ReillyJust when you thought the saga surrounding the Corporate Transparency Act (CTA) couldn’t possibly offer another plot twist, FinCEN delivers yet another exciting eleventh hour surprise. As we previously shared in our last installment, aptly titled “A New Hope,” the Treasury Department announced on March 2, 2025, that it would halt enforcement of the CTA’s Beneficial Ownership Information (BOI) reporting requirements for domestic companies and U.S. persons, even though the CTA remained an enforceable law which required a BOI filing no later than March 21, 2025, for any business entity formed prior to 2024. On March 21, 2025 (yes, the last day for filing) FinCEN solidified this earlier informal position, officially putting these updates into action through the release of an interim final rule (IFR).What exactly is an IFR? It allows an agency like FinCEN to enact regulatory changes immediately, rather than waiting to implement following the typical comment and revision period. This means that these revisions immediately went into effect as of March 21, 2025, though the CTA may still see further changes as FinCEN is accepting comments under the federal rulemaking process prior to issuing the final rule later this year.Most importantly, this IFR completely eliminates all reporting requirements for U.S. formed entities and U.S. persons. The rationale, according to the Treasury Department, is to reduce unnecessary burdens on American businesses and individuals, aligning with broader federal goals aimed at regulatory simplification and economic growth. For those U.S. entities and individuals who proactively filed BOI reports, you did exactly what was required by law at the time. Given the unpredictable twists and turns that the CTA has taken, evidenced by just a few of our many, many, many posts cataloging its evolution, your proactive compliance was prudent based on the information available at the time. The IFR does not address what will be done with BOI reports that have already filed. While likely not relevant to most, foreign companies registered to do business in the United States must still comply with modified CTA reporting obligations. That said, these foreign entities are no longer required to report U.S. persons as beneficial owners. Their new reporting deadlines under the IFR are as follows: Foreign reporting companies registered in the U.S. prior to March 21, 2025, must file their BOI reports within 30 days of the IFR’s publication. Foreign reporting companies registering to do business on or after March 21, 2025, must submit their BOI reports within 30 days from the effective date of their registration.In prior blogs on this subject, we compared the continuing saga of the CTA at different times to both an episodic movie franchise and Yogi Berra’s famous adage that “it’s like Déjá ’ Vu all over again.” In what we believe will be our final blog on the CTA, we need to remind you of another grammatically challenged Berra adage that “it ain’t over ‘til it’s over.” In addition to possible legal challenges to the IFR, numerous existing lawsuits challenging theconstitutionality of the CTA continue to work their way through the legal system. We will, of course, continue to monitor and provide updates should any new information arise, but as the title of this Blog suggests, absent some minor updates to language and other minutia, we believe that this latest development effectively, and unlike a certain sci-fi franchise that doesn’t seem to know when to quit, finally concludes our saga. As always, if you have any questions or require further clarification, please reach out to your Gross McGinley attorney to discuss your specific situation.But remember, it ain’t over ‘til it’s over. May the Force be with you.