Frequently Asked Questions

Do wholly owned subsidiaries have to file the beneficial ownership report to FinCEN?

A subsidiary whose ownership interests wholly owned, directly or indirectly, by certain exempt entities is exempt from the beneficial ownership information reporting requirements. 

A subsidiary whose ownership interests are controlled, directly or indirectly, by certain exempt entities is exempt from the beneficial ownership information reporting requirements. In this context, control of ownership interests means that the exempt entity entirely controls all of the ownership interests in the reporting company, in the same way that an exempt entity must wholly own all of a subsidiary’s ownership interests for the exemption to apply. 

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