In January of this year, we published a Client Alert advising readers that the U.S. Corporate Transparency Act (CTA) had gone effective, requiring many companies and other entities (such as investment vehicles) to file an initial beneficial ownership report (BOR) with the U.S. government. We urge you to read that alert in full, which you can access here.
To summarize, business entities that meet the definition of “reporting company” (and do not fall into any of the 23 exceptions in the CTA) are required to file an initial BOR within the following timeframes:
- Within 90 days after formation of the entity, if the entity was formed in 2024
- By the end of 2024 if the entity was formed before January 1, 2024
- Within 30 days after formation if the entity is formed in 2025 or thereafter
The reporting company definition is very broad and casts a wide net on companies and other business entities that are covered by the BOR filing requirement. The CTA provides for civil (monetary) penalties and criminal penalties for willful failure to make required BOR filings. A variety of corporate services companies, accounting firms, law firms and others are prepared to assist with BOR filings.
Please contact us if you have questions about whether any companies or business entities under your control are required to file a BOR and/or how to complete and file a BOR.
