Who Needs to Report:

Domestic Entities: Corporations, limited liability companies (LLCs), or other entities created in the U.S. by filing with a state or similar office.
Foreign Entities: Companies registered to do business in the U.S. by filing with a state or similar office.

What to Report:

Information about individuals who ultimately own or control the company.

Deadlines:

Existing Companies: Must file by January 1, 2025.
New Companies in 2024: Have 90 days to file after their creation or registration is effective.
New Companies from 2025 Onwards: Will have 30 days to file.

Penalties for Non-Compliance:

Companies that fail to file the required beneficial ownership information may face significant penalties, including civil fines and potential criminal penalties. Non-compliance can result in civil penalties of up to $500 per day until the report is filed, and criminal penalties can include fines up to $10,000 and imprisonment for up to two years.

Legal Challenges:

The CTA is currently facing legal challenges, with a significant case being heard by the 11th Circuit Court of Appeals. The case, National Small Business United v. Yellen, questions the constitutionality of the CTA’s reporting requirements. The outcome of this case could impact the enforcement of the CTA, but a decision is not expected before the January 1, 2025 deadline.

Reports are only required once unless there are updates or corrections needed. For more detailed information, please visit the FinCEN website: https://www.fincen.gov/boi-faqs#B_1

If you have any questions about the CTA, including pending litigation, or help with registration, we encourage you to reach out to your attorney.