FAQ: Corporate Transparency Act Update (12/26/2024)
1. What is the current status of the CTA? The enforcement of the reporting requirement has been reinstated and is now back in effect.
2. What are the applicable deadlines to file?
a. Companies created or registered before January 1, 2024, must file by January 13, 2025 (previously January 1, 2025).
b. Companies created or registered on or after September 4, 2024, with deadlines between December 3, 2024, and December 23, 2024, must file by January 13, 2025.
c. Companies created or registered between December 3, 2024, and December 23, 2024, have an additional 21 days to file (111 days from formation date).
d. Companies created or registered on or after January 1, 2025, must file within 30 days after receiving notice of their formation registration.
e. Note: Companies eligible for disaster relief (e.g., impacted by hurricanes) may have additional extensions.
3. What needs to be done now? If your BOIR filing was halted due to the federal court injunction, it will need to be completed. If your BOIR filing process was not started, you now need to start the process.
4. What will we do next? If we were working on your filing, we will now complete it. Please continue any efforts you may have been working on previously, as this now has to be completed. Our firm will also work to reach out to clients who started the process.
5. What if I already missed the deadline or if beneficial ownership has changed recently? FinCEN has emphasized the importance not to ignore reporting obligations. All entities must file even if they missed the deadline. All entities should notify us of any changes to beneficial ownership since filing. Beneficial owners as defined in the CTA is broader than one may assume for reporting entities, including owners with 25% or more interest, as well as managers, directors, and “Important Decision-Makers” such as key employees, regardless of ownership. The sooner filings are submitted or corrected, the better.
