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.