On January 1, 2024, the Corporate Transparency Act (the "CTA") became effective. For the first time, all US and foreign entities that are determined to qualify as "reporting companies" will be required to report to the U.S. federal government certain company information, including information identifying the individuals who directly or indirectly own or control the entity and the individuals who prepared and filed the formation/registration documents of the reporting company with the Secretary of State (if formed/registered on or after January 1, 2024).
To comply, reporting companies will need to file a Beneficial Ownership Information Report ("BOIR") with the Department of the Treasury's Financial Crimes Enforcement Network ("FinCEN"). The information submitted will be maintained in a centralized, secure nonpublic federal government database, administered by FinCEN. We are here to help you navigate this new regulatory regime (in both French and English) and have summarized below some key points for you to bear in mind. We have also included certain links at the end of this note for your reference, including a link to the French version of the FinCEN Small Entity Compliance Guide.
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The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.