REMINDER:  The Corporate Transparency Act – Comply Before January 1, 2025

By: Robyn Drucker 

The Corporate Transparency Act (CTA) took effect on January 1, 2024. 

As described in Cohen and Wolf’s prior guidance, Getting Ready for the Corporate Transparency Act, and UPDATE: Getting Ready For The Corporate Transparency Act, the CTA requires certain domestic and foreign entities, referred to as “Reporting Companies,” that are not exempt from the requirements of the CTA to report identifying information about their “Beneficial Owners” (a “BOI Report”) to the US Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”).   

BOI Report Filing Deadlines

According to FinCEN’s updated guidance, the following filing deadlines apply to all Reporting Companies:

• A Reporting Company created or registered to do business before January 1, 2024 must file an initial BOI Report on or before January 1, 2025.
• A Reporting Company created or registered on or after January 1, 2024 and before January 1, 2025 has 90 calendar days after it is created to file an initial BOI report.
• A Reporting Company created after January 1, 2025 has 30 calendar days from actual or public notice that the Company’s creation or registration is effective to file an initial BOI report.

BOI Reports can be filed here: File A BOI Report.

Compliance Information

FinCEN has issued certain guidance, including BOI Reporting, Small Entity Compliance Guide and BOI FAQs, which may be used as resource guides for determining reporting obligations.  Additional Resources can be found here: Reference Materials.

Since the CTA became effective, FinCEN’s guidance has been updated to address a number of questions, including the applicability of the CTA to certain types of entities, including without limitation Dissolved Entities and Homeowners Associations. 

Penalties

Failure to comply with the requirements of the CTA carries very significant penalties.  It is critically important that all businesses and business owners review the CTA, including potential exemptions, and comply with all applicable requirements within the required timeframes.

We Can Help

The CTA continues to impact millions of entities doing business in the United States.  Cohen and Wolf’s  Business & Corporate and Tax attorneys are ready to help your business navigate its obligations and reporting requirements under the CTA.

Due to anticipated volume during the month of December, please contact us before December 10, 2024 if you need help determining your CTA obligations or complying with the reporting requirements of the CTA. 

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