The Corporate Transparency Act (the “CTA”) will become effective on January 1, 2024. Entities in existence prior to that date that would otherwise obligated to make filings with the United States Department of the Treasury Financial Crimes Enforcement Network (“FinCEN”) have until January 1, 2025 to comply. However, entities formed after January 1, 2024 had a much shorter compliance period. Under the original regulations promulgated on September 30, 2022, newly formed entities would have only 30 days following “notice of their creation or registration” to comply with the filing requirements. FinCEN published a notice of proposed rulemaking on September 28, 2023 and the final regulations were just promulgated on November 30, 2023 that would extend the initial filing period to 90 days. The new rule, along with the CTA, becomes effective on January 1, 2024. As a result, an entity formed on or after January 1, 2024 but prior to January 1, 2025 that is otherwise obligated to file under the CTA has up to 90 days to comply with the initial filing requirements. Entities formed after January 1, 2025 continue to be subject to the 30-day filing requirement.
The CTA, 31 U.S.C. 5336, can be accessed here: https://www.fincen.gov/sites/default/files/shared/Corporate_Transparency_Act.pdf
Regulations under the CTA, 31 CFR 1010.380, can be accessed here:
https://www.fincen.gov/sites/default/files/shared/31_CFR_1010_380_excerpt_from_Final_Rule.pdf
Final rule extending the initial reporting period can be accessed here:
https://www.govinfo.gov/content/pkg/FR-2023-11-30/pdf/2023-26064.pdf
Reach out to Liskow attorneys Marilyn Maloney, Leon Rittenberg, and Julie Chauvin for further information regarding the Corporate Transparency Act, and visit our resource page here.
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