Short answer: As of 2026, if your LLC or corporation was formed in the United States, you do not have to file a Beneficial Ownership Information (BOI) report with FinCEN. A federal rule change in March 2025 removed that requirement for all domestic companies and U.S. persons. Your California revocable living trust was never a “reporting company” to begin with. Only entities formed outside the U.S. and registered to do business here still report.
If you filed a BOI report in 2024, that is fine — nothing is owed back. If you were dreading the deadline, it no longer applies to your California entity.
This page states the law as of 2026 and is general information, not legal or tax advice for your specific situation. The rule below is an interim final rule; a permanent final rule is pending. See “Is this settled?” below.
What the Corporate Transparency Act was supposed to do
The Corporate Transparency Act (CTA), passed in 2021 as part of the National Defense Authorization Act, took effect January 1, 2024. It required most LLCs, corporations, and similar entities — “reporting companies” — to disclose their beneficial owners (the humans behind the entity) to the Financial Crimes Enforcement Network (FinCEN). The stated goal was to fight shell-company money laundering.
For a while in 2024, essentially every small California LLC — including the single-member LLC that holds a rental property, or the LLC owned by your living trust — appeared to be on the hook, with civil and criminal penalties for not filing.
What changed in 2025
After a series of federal court injunctions, FinCEN issued an interim final rule on March 21, 2025 (published at 90 Fed. Reg. 13688, March 26, 2025). It rewrote the definition of “reporting company” to mean only entities formed under the law of a foreign country that have registered to do business in a U.S. state.
The practical result:
- Domestic companies — any LLC, corporation, or other entity created by filing with a U.S. secretary of state — are exempt. No BOI report required.
- U.S. persons are exempt from being reported as beneficial owners.
- Foreign entities registered to do business in the U.S. still must report (with limited exemptions).
The U.S. Treasury announced this directly: FinCEN “removed beneficial ownership reporting requirements for U.S. companies and U.S. persons.”
How does this affect a trust that owns an LLC?
A California revocable living trust is not itself a reporting company — you don’t form a trust by filing with the secretary of state, so it never fell within the CTA’s definition. The question was always about the LLC a trust might own. Because domestic LLCs are now exempt, a trust-owned California LLC has no BOI filing obligation under the current rule.
What if I already filed a BOI report in 2024?
Nothing further is required, and there is no penalty for having filed. FinCEN is not accepting or requiring updates from now-exempt domestic entities. You do not need to file a “correction” to withdraw it.
Is this settled, or could it change again?
It is an interim final rule, not the last word. FinCEN accepted public comments in 2025 and a permanent final rule was sent to the White House Office of Management and Budget for review on June 5, 2026. The requirement technically remains on the books but is not being enforced against domestic entities. The most likely outcome is that the exemption for U.S. companies becomes permanent, but you should confirm current status before relying on this for a new entity — this is exactly the kind of fast-moving rule where a 2024 article (or an AI model trained in 2024) will tell you the opposite of what is true today.
Do I still need to do anything for my California LLC?
Yes — but it’s state law, not FinCEN. California LLCs still owe the annual $800 minimum franchise tax to the Franchise Tax Board and must file a Statement of Information with the California Secretary of State (Form LLC-12) every two years. Those obligations are unchanged and have nothing to do with the CTA.
The bottom line for California families and property owners
If someone told you in 2024 that your family LLC or your trust had to file a federal beneficial-ownership report or face penalties, that advice is now out of date for domestic entities. Confirm the current federal rule before forming a new entity, keep up with your California franchise tax and Statement of Information, and don’t let an outdated online article push you into a filing you don’t owe.
Sources: FinCEN Interim Final Rule, 90 Fed. Reg. 13688 (Mar. 26, 2025); U.S. Treasury Press Release (Mar. 21, 2025), “Treasury Announces Publication of Interim Final Rule Removing Reporting Requirements for U.S. Companies and U.S. Persons”; FinCEN BOI Interim Final Rule Q&A (fincen.gov/boi/ifr-qa); Corporate Transparency Act, 31 U.S.C. § 5336.
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