Veto of NY LLC Transparency Act Amendment
As discussed on page 78 of the Tax Year 2025 M+O=CPE Individual Tax Reference Book, the New York LLC Transparency Act, which was last amended on March 1, 2024, follows the federal law and regulations when determining which limited liability companies (LLCs) are required to report information about their beneficial owners to New York.
Since the federal regulations now indicate that only entities organized outside the United States and doing business in the United States are required to report owner information under the federal law, the New York law similarly requires that only LLCs that are organized outside of the United States and doing business in New York are required to report owner information to New York.
A bill that would have amended the New York law to require all LLCs to report owner information to New York had passed both the New York Assembly and Senate during 2025. (The bill was Senate Bill S8432.) However, on December 19, 2025, the Governor vetoed the bill.
While it is possible that new legislation may be proposed again that could broaden the requirements of the LLC Transparency Act, the current New York law, which became effective on January 1, 2026, requires that only LLCs formed under the laws of a foreign country and doing business in New York are required to report owner information to New York.
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