We continue to monitor Corporate Transparency Act (CTA) developments.

This update includes the news that as of January 3, 2024, the Financial Crimes Enforcement Network (FinCEN), the bureau responsible for enforcing CTA provisions, has established its system for online filing of beneficial ownership information.

Reporting companies required to file beneficial ownership information will do so on FinCEN’s website https://www.fincen.gov/boi.

All domestic and foreign reporting companies created or registered on or after January 1, 2024, must file their initial report within 90 days of receiving notice of their creation or registration. All domestic and foreign companies created or registered before January 1, 2024, must file their initial report no later than January 1, 2025.

Penalties are imposed for persons who willfully fail to complete the information. Such persons are liable for $500 per day the violation continues or $10,000 for a criminal violation. Person includes any individual, reporting company, or “other entity.”

The website is currently operational. In testing the site, the process is pretty straight forward, but does require a lot of information from both the entity and beneficial owners (including pictures of identification).

At this time, Ketel Thorstenson LLP’s role related to the CTA will be limited to providing education and awareness and answering questions about the new reporting requirements. The CTA does not involve either the Treasury Department or the IRS and no CTA disclosures are required with any federal or state tax filings. Consequently, Ketel Thorstenson LLP is currently not allowed to be responsible for any client FinCEN filings. Ketel Thorstenson, LLP will continue to monitor this closely in regard to how we can assist taxpayers with this new reporting requirement.

For a general background on the CTA:

Making Translucency Out of Transparency: Our Take on the Corporate Transparency Act

The Corporate Transparency Act: An Update

The Corporate Transparency Act: Update II