Following our January 2024 update regarding the U.S. Corporate Transparency Legislation, companies formed or registered in the United States before January 1, 2024, must file an electronic Beneficial Ownership Information Return (BOIR) with the Financial Crimes Enforcement Network (FinCEN) under the Corporate Transparency Act (CTA). This requirement applies to both U.S.-based businesses and foreign entities doing business in the United States. The return must be filed no later than January 1, 2025, unless your entity is out of scope or eligible to claim an exemption from filing. This deadline applies to entities that were in existence in 2024 that are in the process of dissolving or have recently dissolved.
We urge you to evaluate how this new, expansive federal filing requirement impacts entities that you own or control, including corporations, limited liability companies, statutory trusts, and other similar entities. Failure to file a BOIR may result in civil and criminal penalties.
If you need assistance determining your filing obligations or have any questions, please don’t hesitate to contact us.
