As you may know, the Corporate Transparency Act (the “CTA”) took effect on January 1, 2024, imposing reporting and disclosure requirements on new and existing business entities. The CTA requires legal entities operating in the United States to file beneficial ownership information (“BOI”) reports with the Financial Crimes Enforcement Network (“FinCEN”). Most small businesses and holding companies are required to file BOI reports. Information about exemptions is available from FinCEN here. Failure to file if required and filing inaccurate or incomplete reports can result in significant monetary penalties against entities and individuals and imprisonment of up to two (2) years.
For entities which are not exempt from CTA reporting requirements, the filing deadlines are:
- January 1, 2025 for entities formed before January 1, 2024
- Within ninety (90) days of formation if formed in 2024
- Within thirty (30) days of formation if formed on or after January 1, 2025
BOI reports can be filed directly with FinCEN for no fee at https://boiefiling.fincen.gov.
Gravel & Shea PC is available to assist with:
- determining whether a BOI filing is required or whether exemptions apply
- analyzing who is a beneficial owner for reporting purposes
- filing BOI reports
If you have questions or would like CTA-related assistance, please contact Annie Harb (aharb@gravelshea.com) or Alyssa Bachand (abachand@gravelshea.com) no later than November 15, 2024. If you do not contact us by November 15, we will not be able to provide assistance related to the CTA.