As a reminder following our last update, the reporting deadlines under the Corporate Transparency Act (“CTA”) which took effect on January 1, 2024, are fast approaching.
The CTA requires both domestic and foreign “reporting companies” to file beneficial ownership information reports (“BOI Reports”) with the US Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”).
Reporting companies include LLCs, corporations, or any other entities formed by filing a document with a secretary of state or other similar office, or a foreign company that is registered to do business in any state, and that does not qualify under one of the 23 exemptions enumerated in the CTA. A list of the exemptions can be found on FinCEN’s FAQ website.
Deadlines for Reporting Companies to File Initial BOI Reports
- Existing Companies (formed before January 1, 2024): January 1, 2025
- Newly Formed Companies (formed in 2024): 90 calendar days after formation
- Newly Formed Companies (formed in 2025 and beyond): 30 calendar days after formation
Updated Reports: Although there is no annual filing requirement for BOI Reports, if there are any changes to the required information previously submitted about the reporting company or its beneficial owners, the company must file an updated report within 30 calendar days after a change occurs.
For any questions about the Corporate Transparency Act or the Beneficial Ownership Information Reports, please contact one of our Corporate Attorneys.
