The Corporate Transparency Act. Beneficial Ownership Information Reporting | FinCEN

What is the Corporate Transparency Act (CTA)?

The CTA is a new federal law effective January 1, 2024.

The CTA’s purpose is to increase transparency in business ownership and structure to help fight financial crimes like money laundering and tax evasion by requiring companies to disclose key information about their owners.

Who does The CTA Apply To?

Domestic Reporting Company: a corporation, limited liability company (LLC), or any other entity created by the filing of a document with a secretary of state or similar office.

Foreign Reporting Company: a corporation, LLC, or other entity formed under the law of a foreign country that is registered to do business in the United States by the filing of a document with a secretary of state or similar office.

Non-Reporting Companies include entities that are not created by filing with a secretary of state, e.g., sole proprietorships and certain trusts.

Exempt Companies include banks, credit unions, tax-exempt entities, public utilities and certain large companies.

What information must be reported?

Your reporting company must provide information about itself:

• Legal name
• Any trade name or any “doing business as” (d/b/a)
• Complete U.S. address
• State, Tribal, or foreign jurisdiction or formation
• For a foreign reporting company: State or Tribal jurisdiction of first registration
• Taxpayer Identification Number (TIN) or foreign tax ID

What Specific Information Must be Reported About Beneficial Owners and Company Applicants?

• Name
• Date of birth
• Address

Identifying number and issuing jurisdiction from a non-expired driver’s license, U.S. passport, or an identification document issued by a State, local government, or Indian tribe, or a foreign passport. An image of the document must also be provided.

What are The Reporting Deadlines?

Existing, created or registered to do business in the Unites States before January 1, 2024. Reports due by January 1, 2025

New, created or registered to do business in the United States on or after January 1, 2024. For new reporting companies created or registered during 2024, reports are due within 90 calendar days of receiving actual or public notice that the reporting company’s creation or registration is effective. Starting January 1, 2025 new reporting companies will have 30 calendar days to file.

What is the Impact on CTA Requirements Pending its Challenge on Appeal?

Despite the legal challenges the CTA is facing, businesses are still expected to comply with the CTA’s reporting requirements. While the law remains in effect, the appeals process could lead to delays, changes, or even the potential overturning of certain provisions.

The Deadline For The Corporate Transparency Act Is Fast Approaching. We’ll Help You Maintain Compliance. Contact our Office to File your Beneficial Owner Information (BOI) Report with The Financial Crimes Enforcement Network (FinCEN) today.

For more information contact us at (415) 657-6090