Does NY Corporate Transparency Act Apply Only to Foreign LLCs?

The New York LLC Transparency Act (NYLTA), which is modeled on the federal Corporate Transparency Act (CTA), takes effect on Jan. 1, 2026. As originally written, LLCs formed or authorized to do business in New York were required to provide information about each beneficial owner. However, on March 26, 2025, the Treasury Department removed the requirement for U.S. companies and U.S. persons to report beneficial ownership information to the Financial Crimes Enforcement Network under the CTA and narrowed the scope of the rule to foreign reporting companies. Because many key terms of NYLTA cross-reference the CTA, without statutory amendments, NYLTA would only apply to foreign LLCs authorized to do business in New York.

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Robert Friedman, Esq.

Partner/Attorney Hamline University School of Law, New York State Bar, U.S. District Court for the Western District of New York

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