Understanding Your Responsibilities Under the Corporate Transparency Act
Legal Alerts
8.15.24
Beginning on January 1, 2024, the Corporate Transparency Act (the “CTA”) requires many entities formed or registered to do business in the United States to report information to the U.S. Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”). For each reporting company, this includes detailed information about the company and its beneficial owners, and for newly formed entities, individuals involved in the formation of the company.
This alert describes in detail the CTA, its consequences, and your potential responsibilities under the CTA. Most notably, the CTA provides for 23 exemptions from such FinCEN reporting requirements, including for any “large operating company,” as defined under the CTA. Click here for more information on the definition of exempt companies and non-exempt (“reporting”) companies.
Reporting companies must file an initial “beneficial ownership interest” (“BOI”) report within the following timeframes: (i) reporting companies formed or registered before January 1, 2024, have until January 1, 2025, to file a BOI report; (ii) reporting companies formed or registered in 2024 have until 90 days after formation or registration to file the initial BOI report; and (iii) reporting companies formed or registered after January 1, 2025, will have until 30 days after formation or registration to file the initial BOI report. Reporting companies will also be required to update their filings with FinCEN within 30 days of any change to previously reported information.
If your company is a reporting company under the CTA, you will be responsible for submitting BOI filings and all other related reports and information to FinCEN, as defined and required by the CTA. A PDF of the form for reference purposes may be found here. You may either file the BOI report yourself using the filing portal or you may click on any of the following links to the CTA Resource Page of one of our regular third-party vendors.
Dykema will continue to assist clients with entity formations and filings with the secretary of state or any similar offices and is happy to assist if analysis is required with respect to what information may be necessary for the filing. If you have any questions about the CTA, please do not hesitate to contact us.
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| Dissolving your business before January 1, 2025? According to some recent guidance regarding the Corporate Transparency Act, you might still have outstanding paperwork to file with FinCEN. | Teresa Ereon Giltner and Kacy Cigarroa discuss what investors need to understand about the CTA, how it applies to them, and how to navigate its complexities to ensure their holdings remain compliant and transparent. | Starting January 1, 2024, the Corporate Transparency Act (CTA) imposed new reporting obligations upon millions of companies doing business in the United States. Here’s a primer on what businesses need to know. |
FinCEN Resources
