The Corporate Transparency Act (CTA) requires 1) domestic (U.S.) entities and 2) foreign entities registered to do business in the U.S. (collectively, "Reporting Companies") that were in existence prior to Jan. 1, 2024, to file an electronic Beneficial Ownership Information Return (BOIR) with the Financial Crimes Enforcement Network (FinCEN), a unit of the U.S. Department of the Treasury. The return must be filed no later than Jan. 1, 2025, unless the entity is 1) out of scope or 2) eligible to claim an exemption from filing. (BOIR filings also are required for Reporting Companies formed in 2024, which have a 90-day deadline from formation or registration to file a BOIR, unless out of scope or exempt under the CTA.)
Consider how this new, expansive federal filing requirement may impact entities that you own or control, including corporations, limited liability companies, statutory trusts and other similar entities.
A failure to file a BOIR may result in civil and criminal penalties.
The Jan. 1, 2025, deadline applies to entities that are in existence in 2024 that are in the process of dissolving or have recently dissolved.
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.
