FinCEN has issued an interim final rule that removes the requirement for U.S. companies and U.S. persons to report BOI to FinCEN under the CTA. There may be limited scenarios in which a foreign-domiciled fund portfolio company or entity within a foreign fund structure meets the definition of a reporting company and requires reporting of its non-U.S. beneficial owners. The firm should consult with counsel if there are any questions as to whether or not an exemption applies to a given entity.