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ARTICLE · 29 SEPTEMBER 2023

The Corporate Transparency Act: An Update

Proposed Extension of Due Date for Reporting Initial Beneficial Ownership Information and Other Developments...

United StatesCorporate/Commercial Law

Highlights

  • The Financial Crimes Enforcement Network (FinCEN) on Sept. 27, 2023, issued a Notice of Proposed Rulemaking that, if finalized, would extend the deadline from 30 days to 90 days for "Reporting Companies" formed in 2024 to file their Initial Beneficial Ownership Information Reports.
  • FinCEN's primary rationale for this proposed extension is to reduce compliance burdens on Reporting Companies.
  • No other changes to the final beneficial ownership information reporting rule were made.

The Corporate Transparency Act (CTA) will be effective on Jan. 1, 2024. For the first time, the United States now will require certain legal entities to report to the federal government identifying information about the individuals who directly or indirectly own or control a company within the scope of the new legislation. This information will be housed in a centralized, secure nonpublic federal government database to be administered by the Financial Crimes

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