Client Alert
By Attorney Andrew Newcombe
September 11, 2024
The Corporate Transparency Act (CTA) went into effect on January 1, 2024. This law applies to most private companies doing business in the United States. Companies subject to the CTA and not eligible for one of several specified exemptions (Reporting Companies) are now required to submit Beneficial Ownership Information (BOI) Reports to the Financial Crimes Enforcement Network (FinCEN). Failure to comply with this new federal reporting requirement may result in both civil and criminal penalties.
For Reporting Companies that were formed or registered to do business in the United States prior to January 1, 2024, the deadline to file an initial BOI Report with FinCEN is December 31, 2024. For Reporting Companies formed or registered during 2024, the deadline to file an initial report is 90 days from the date of formation or registration. Beginning in 2025, the initial report deadline will drop to 30 days from the date of formation or registration. For more information about the CTA, please refer to our previous client alerts on this topic located here.
We are available to advise and assist clients in completing their CTA reporting obligations and compliance. We anticipate a significant increase in inquiries on this topic as the year-end deadline approaches. If you have questions about your company’s obligations under the CTA that you wish to discuss before the filing deadline, please reach out to your Sheehan Phinney team to schedule a consultation now.
This article is intended to serve as a summary of the issues outlined herein. While it may include some general guidance, it is not intended as, nor is it a substitute for, legal advice.