Although the Corporate Transparency Act (the "Act")
was adopted in 2021, implementation has been delayed while the
Department of Treasury's Financial Crimes Enforcement Network
("FinCEN") established regulations. The deadline,
however, for compliance is fast approaching. Reporting Companies
(as defined) formed after January 1, 2024, will need to file
reports within 30 days after formation. Reporting Companies already
existing at the end of 2023 will need to make their initial reports
before the end of 2024.
The Act seeks to obtain Beneficial Ownership Information
("BOI") on individuals who own substantial pieces of, or
otherwise control, Reporting Companies. It is the latest effort by
the federal government to combat money laundering, tax fraud, and
other illegal activity by bad actors. Unfortunately, a lot of good
actors will get caught in the crossfire.