On January 1, 2024, the Corporate Transparency Act (CTA) went into effect requiring millions of entities operating in the United States to report their Beneficial Ownership Information (BOI). The Corporate Transparency Act requires reporting organizations to submit BOI to the Financial Crimes Enforcement Network (FinCEN) and to notify the agency of any changes to the information that they reported as they occur. You may file the BOI online HERE. 

Although our firm is not doing the actual filings, we can recommend a third-party service provider that can file the report on your behalf. Please contact us for additional guidance. 

Understanding the CTA and BOI.

Under the Corporate Transparency Act, entities will be required to file a detailed report with information about the beneficial owners and the individuals who have substantial control of the company. Failure to comply can result in significant penalties, including imprisonment, and fines of up to $500 per day for both the company and the individuals involved.

• A domestic reporting company created before January 1, 2024, must file its initial BOI report by January 1, 2025. 

• A domestic reporting company created on or after January 1, 2024, and before January 1, 2025, must file a report within 90 calendar days of the date on which it receives actual or public notice that its creation has become effective.  

• A domestic reporting company created on or after January 1, 2025, must file a report within 30 calendar days of the date on which it receives actual or public notice that its creation has become effective.

A “Reporting Company” is a domestic or foreign corporation, limited liability company, or similar entity that was either formed or registered to do business in any state or jurisdiction by filing a document with a secretary of state or other similar office and which does not qualify for an exemption. For reporting purposes, a beneficial owner is any individual who, directly or indirectly, exercises substantial control over the reporting company or owns or controls at least 25% of the ownership interests of the reporting company.

What information must be reported for each of the beneficial owners and applicants?

The report must set forth their (1) full legal name, (2) date of birth, (3) complete current residential street address (except in the case of a company applicant who forms or registers an entity in the course of the company applicant’s business, who has to provide the street address of the business), (4) unique identifying number and the issuing jurisdiction from either a current (i) U.S. passport, (ii) state or local ID document, (iii) driver’s license, or (iv) if the individual has none of those, a foreign passport, and (5) an image of the document from which the unique identifying number was obtained.

Additional information

Additional details on the BOI requirements can be found here, as well as in these Frequently Asked Questions from FinCEN. 

Questions? Email us!