January 1, 2025 is the deadline for the Beneficial Ownership Information Initial Report for all existing Reporting Companies under the Corporate Transparency Act.
Amy E. Coleman November 14, 2024
McGrath McCall, P.C.
The filing deadline for businesses to report their operation details, as required by the Corporate Transparency Act (31 USC § 5336) (“CTA”), is soon approaching.
Under CTA the and rules promulgated by the Financial Crimes Enforcement Network (“FinCEN”) (31 CFR § 1010.380), all entities that qualify as a “Reporting Company” must disclose all “Beneficial Owners” in an initial report to be submitted based upon the following deadlines based upon the date of formation (or the date of receipt stamped on your initial filing).
Date of Formation | Deadline for Submission of the BOI Initial Report |
Prior to January 1, 2024 | January 1, 2025 |
January 1, 2024-December 31, 2024 | Within 90 calendar days after formation |
January 1, 2025 and later | Within 30 calendar days after formation |
A separate BOI Initial Report is required to be submitted for each “Reporting Company” and includes information regarding the entity itself, any “Beneficial Owners,” and a Company Applicant (if formed after January 1, 2024).
To file, please visit the FinCEN website, where you can submit via webpage or PDF.
If you have any questions about whether your entity qualifies as a “Reporting Company, how to identify “Beneficial Owners,” or any other questions about the BOI Initial Report, please contact our firm and we would be happy to assist you. While there are several exceptions as to what is classified as a “Reporting Company,” those exceptions are fact-specific and most for-profit entities and small businesses are unlikely to qualify for one. In addition, all businesses are encouraged to consult with their accountant or tax counsel before submission of the BOI Initial Report to ensure all information is consistent with any prior filings or beneficial ownership information documentation previously reported related to financing.
Businesses are encouraged to save a copy of the transcript of the BOI Initial Report, which is available for download after submission, with their corporate records and notify any financial institution with which they have any financing in place to inform them of any corporate changes. Please note that after submission of the BOI Initial Report, each entity is also under an obligation to file an updated BOI Report within 30 calendar days of your awareness of any error or changes to the information submitted in the BOI Initial Report.
Amy E. Coleman, Esq. is an Associate Attorney for McGrath McCall, P.C.
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