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As we reported in August 2023, the Corporate Transparency Act (the "CTA") will become effective on January 1, 2024. For the first time, the United States government will require certain U.S. business entities and foreign entities registered to do business in the U.S. to disclose information regarding their beneficial owners to the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN).
Specifically, entities created before January 1, 2024, will have until January 1, 2025, to file their beneficial ownership information report ("BOI") with FinCEN. Entities formed after January 1, 2024, however, will need to file within 30 days after formation.
Despite the broad inclusion of entities under the CTA's definition of Reporting Company, there are certain entity types that are exempt from reporting to FinCEN.
We recommend that you begin to assess whether your business is subject to the CTA compliance or falls within one of the exemptions and begin to collect BOI if a reporting is mandatory for your business under CTA.
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