Corporate Transparency ACT
Corporate transparency Act: Beneficial Ownership Information Report Filing Requirements
As you may be aware, on January 1, 2024, new reporting requirements came effect related to the Corporate Transparency Act ("CTA") passed by Congress in 2021. The reporting requirements apply to many businesses operating in the United States. Businesses that may be subject to the reporting requirement include:
Limited Liability Companies (“LLCs”);
Limited Partnerships;
Corporations; and
Any similar entity created by the filing of a document with a secretary of state or similar office.
If you have a business of any type listed above, you may have to comply with the reporting requirements by filing an initial Beneficial Ownership Information Report (“BOI Report”) with the Financial Crimes Enforcement Network (“FinCEN”) on their website: https://www.fincen.gov/boi.
In the initial BOI Report, you will need to report specific information about your business (the “Reporting Company”), its Beneficial Owners, and if your business was created after January 1, 2024, you will need to report its Company Applicant. You can find information on FinCEN's website to assist you in identifying Reporting Companies, Beneficial Owners, Company Applicants, and whether your business is exempt from the CTA’s reporting requirements.
Following a series of legal developments in Smith v. United States Department of the Treasury and Texas Top Cop Shop, Inc. v. McHenry (formerly Texas Top Cop Shop v. Garland), the CTA's reporting requirement has been reinstated with filing deadlines as follows:
Reporting Companies created or registered on or before February 19, 2025: The deadline to file an initial Beneficial Ownership Information Report is March 21, 2025.
Reporting Companies that have already filed their initial reports but need to update or correct them: The deadline to submit updated or corrected reports is March 21, 2025.
Reporting Companies created on or after February 20, 2025: The deadline to file the initial report is 30 days after the company’s creation or registration.
In addition to the initial filing requirement, the CTA requires that Reporting Companies maintain ongoing compliance by reporting any changes to Beneficial Ownership Information within 30 days of such change.
If you would like to engage our services to assist you in complying with the Corporate Transparency Act, please contact us by email at cta@bllawgroup.com with your name, the name of each of your entities, and the name of the Ball, Loudon, Ebert, & Brostrom, LLC attorney with whom you work.
We will not take any action on your behalf unless we are specifically engaged by you to do so.