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ARTICLE · 05 DECEMBER 2023

Corporate Transparency Act: Final Rule Extending Certain Reporting Dates

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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...

United StatesCorporate/Commercial Law
Marilyn Maloney
Marilyn Maloney
Leon H. Rittenberg III
Leon H. Rittenberg III
Julie S. Chauvin
Julie S. Chauvin
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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

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