On December 19, Gov. Kathy Hochul vetoed New York Senate Bill 8432 (S8432) and its Assembly companion, A8662A. The legislation would have amended the New York LLC Transparency Act (NYLTA) to preserve beneficial ownership reporting requirements for domestic New York LLCs.
The bill was intended to restore the Legislature’s original intent when the NYLTA was enacted—namely, that domestic New York LLCs would be subject to state-level beneficial ownership reporting. The amendment became necessary after federal rulemaking under the Corporate Transparency Act (CTA) narrowed the definition of “reporting company” to exclude most U.S.-formed entities.
Because the bill was vetoed, the NYLTA remains tied to the CTA’s current definitions. As a result, the NYLTA now effectively applies only to LLCs formed in foreign countries that are authorized to do business in New York. Domestic New York LLCs will not be subject to beneficial ownership reporting under the NYLTA unless future legislative action is taken.
We will continue to monitor developments and provide updates if the Legislature revisits this issue.
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