The Corporate Transparency Act (CTA), enacted as part of the National Defense Authorization Act for Fiscal Year 2021, requires certain entities to disclose information about their “beneficial owners.” A beneficial owner is defined as any individual who owns or controls at least 25% of the entity or has significant control over it. This disclosed data is referred to as “beneficial ownership information” (BOI).
CTA and Its Purpose
The CTA is part of the Bank Secrecy Act, not the tax code. This federal law mandates record-keeping and reporting for certain entities. Its primary goal is to help U.S. law enforcement combat money laundering, terrorism financing, and other illicit activities.
Who Needs to File?
Most corporations, LLCs (including single-member LLCs), and limited partnerships must comply with the CTA’s filing requirements. While there are some exceptions, entities existing as of January 1, 2024, must submit an initial filing by January 1, 2025. Afterward, updates are only required when specific information changes. For entities created after January 1, 2024, consult your legal advisor to determine compliance requirements.
Filing Assistance Options
We’re here to guide you through your filing requirements and help you explore your options. Below are three recommended approaches:
Option 1: File with Support from FileForms
For a guided filing experience, assistance in securely collecting identity documents (e.g., driver’s license or passport) from beneficial owners, or managing frequent updates, we recommend FileForms. Use the promo code FILE20 to receive 20% off all services (no expiration). FileForms specializes in BOI reporting and works closely with the Treasury Department to ensure compliance. Their user-friendly software simplifies the process, especially for complex filings.
Option 2: File Directly with the Treasury Department
If you prefer a self-guided approach, you can file directly with the Treasury Department at no cost. Visit FinCEN.gov to complete the form online or upload a PDF version of the report.
Option 3: Seek Assistance from an Attorney
You may also consult the attorney who established your entities or work with a local attorney experienced in BOI reporting. If you need recommendations, please let us know.
For questions about your filing requirements or assistance in determining the best approach, please reach out to your HoganTaylor service team.
The HoganTaylor Tax Practice
If you have any questions about the content of this publication, or if you would like more information about HoganTaylor's Tax practice, please email Tony Otto, Tax Practice Lead, at jotto@hogantaylor.com.
INFORMATIONAL PURPOSE ONLY. This content is for informational purposes only. This content does not constitute professional advice and should not be relied upon by you or any third party, including to operate or promote your business, secure financing or capital in any form, obtain any regulatory or governmental approvals, or otherwise be used in connection with procuring services or other benefits from any entity. Before making any decision or taking any action, you should consult with professional advisors.
