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Who must report?
Companies that are required to register with their state Secretary of State must register with
the Financial Crimes Enforcement Network (FinCEN). These entities include LLCs, corporations
and partnerships.
What companies are exempt?
The Corporate Transparency Act includes a number of exemptions including large entities that [1] employ more than 20 full-time employees, [2] gross more than $5 million/year, and [3] have a physical presence within the US. Tax-exempt entities are also exempt.
What must companies report?
Companies must report “beneficial ownership” information. A beneficial owner is someone who
exercises substantial control over the company or owns 25% or more of the company.
Companies must report the following information for beneficial owners:
- Legal name
- Date of birth
- Residential address
- Driver’s license or passport information
Alternatively, individuals may apply for a FinCEN identifier and provide the identifier
to the reporting entity instead.
What are the deadlines?
Companies created before 2024 have until January 1, 2025 to register.
Companies created in 2024 have 90 days to register.
Companies created after 2025 have 30 days to register.
Once a company reports, the company has 30 days to provide updated filing information
in the event of a change.
Who files this information?
Your tax advisor or your attorney may be able to assist. CT Corporation and Harbor Compliance
offer a filing service for a fee. You may also self-prepare. https://boiefiling.fincen.gov/
