The Corporate Transparency Act (CTA) became federal law in 2021. Under it, certain companies report their real owners to the Financial Crimes Enforcement Network (FinCEN), a bureau inside Treasury. The ownership report is called beneficial ownership information (BOI). In 2026 a company that a state filing created does not file, and that covers every Illinois LLC and corporation. This page is for owners in India, Canada or the United States who run a U.S. business from abroad or plan to register a foreign company in Illinois.
Who does the Corporate Transparency Act cover?
| Company | Files a BOI report? | Basis |
|---|---|---|
| Set up by filing with a secretary of state in a state or tribe (any Illinois LLC, corporation or LP), whoever owns it | No | Domestic-entity exemption |
| Formed under the law of another country, registered in a U.S. state to do business there | Yes, unless exempt | 31 CFR 1010.380(c)(1)(ii) |
| Fits one of 23 other exemption types, such as banks, insurers and tax-exempt groups | No | 1010.380(c)(2) |
| Large operating company: more than 20 full-time U.S. employees, a U.S. office, and over $5,000,000 in U.S.-source receipts | No | 1010.380(c)(2)(xxi) |
| A beneficial owner who is a U.S. person | Not reported | 1010.380(b)(5) |
What does it mean for a foreign-owned or cross-border business?
| Situation | What the law says | What to check |
|---|---|---|
| Indian or Canadian owner of an Illinois LLC | The LLC is a U.S. company, exempt whoever owns it | It was created by an Illinois filing, not registered as a foreign company |
| Indian or Canadian company registered in Illinois | A reporting company unless exempt | Registration date, exemptions, the 30-day clock |
| Foreign company owned only by U.S. persons, such as U.S. citizens in Naperville | Still files, but without owner details | Whether each owner is a "U.S. person" under the tax code |
| Non-U.S. owner of a foreign reporting company | Reported with identity details | Who holds 25 percent or control |
The rules, numbers and checklist page has deadlines and penalties. Foreign accounts fall under the Bank Secrecy Act and FBAR. For Illinois background see foreign qualification in Illinois, the foreign-owned LLC guide, the Illinois LLC Act and the ownership register comparison.
Frequently asked questions
Does my Illinois LLC owned from India or Canada file a BOI report?
No. Whoever owns it, a company that a state filing created is exempt. Our BOI status update tracks changes.
Official sources
- FinCEN: Beneficial Ownership Information reporting
- Federal Register: Beneficial Ownership Information Reporting Requirement Revision, final rule
- eCFR: 31 CFR 1010.380, reports of beneficial ownership information
- eCFR: 31 CFR 1010.821, penalty adjustment table
- Cornell Law School: 31 U.S.C. 5336, beneficial ownership information reporting
This page summarizes public guidance in plain language. If anything here differs from the official source, the official source controls.