On July 8, 2024, the Financial Crimes Enforcement Network (“FinCEN”) issued additional FAQs relating to the Corporate Transparency Act (the “CTA”). More specifically, FinCEN provided helpful guidance pertaining to the reporting requirements of companies created or registered on or after January 1, 2024 that later wind up their affairs and cease to exist before their initial beneficial ownership information (“BOI”) report is due to FinCEN.
As a reminder, reporting companies created or registered on or after January 1, 2024 must report their BOI to FinCEN within ninety (90) days of receiving actual or public notice that its creation or registration is effective. Reporting companies created or registered on or after January 1, 2025 must report their BOI to FinCEN within thirty (30) days of receiving such notice.
The FAQs clarify that the obligation to make the initial BOI report remains even if a reporting company winds up their affairs and ceases to exist as a legal entity before their initial BOI report is due. However, there is no obligation for the reporting company to file an additional report with FinCEN noting that the company has ceased to exist after the company files the initial BOI report.
KMK’s CTA team is continuing to monitor guidance issued on the CTA and will provide updates as necessary. Please reach out to KMK’s CTA Team with any questions or concerns.
KMK Law articles and blog posts are intended to bring attention to developments in the law and are not intended as legal advice for any particular client or any particular situation. The laws/regulations and interpretations thereof are evolving and subject to change. Although we will attempt to update articles/blog posts for material changes, the article/post may not reflect changes in laws/regulations or guidance issued after the date the article/post was published. Please consult with counsel of your choice regarding any specific questions you may have.
ADVERTISING MATERIAL.
© 2024 Keating Muething & Klekamp PLL. All Rights Reserved
PartnerAs a partner in the firm’s Business Representation & Transactions Group, Allie Westfall’s insight and proven analytical skills help translate the complexities of the often-challenging securities laws. Allie’s counsel ...
AssociateKassidy Michel practices in the firm’s Real Estate Group where she advises clients on a wide variety of commercial real estate and business transactions, including the acquisition, sale, financing, development and leasing of ...
Subscribe
RSS Feed
Follow us on Facebook
Follow us on Twitter
Follow us on LinkedInTopics/Tags
Select- Securities Law
- SEC
- Nasdaq
- Corporate Transparency Act
- Cybersecurity and Privacy Law
- Securities Regulation
- Cybersecurity Regulation
- IRS
- Corporate Law
- Tax Planning
- Coronavirus
- Clawback Rules
- SEC Enforcement
- Taxation
- Dodd-Frank
- Mergers & Acquisitions
- Paycheck Protection Program
- JOBS Act
- Corporate Tax
- Economic Sanctions
- Ohio LLC Act
- FAST Act
- Corporate Governance
- Consumer Protection Act
- Proxy Access Rules
- Securities Litigation
- Crowdfunding
- Conflict Minerals
- Cryptocurrency
- Hedging
- Real Estate Law
- Emerging Growth Companies
- Investors
- Pay Ratio Disclosure
- Whistleblower
- Private Offerings
- Intellectual Property
- Technology
- Opportunity Zone
- LIBOR
- Executive Compensation
- Health Care Act
- Accredited Investors
- Sales Tax
- United States Supreme Court
- Online Trading Platforms
- Wall Street Reform
- IPO
- Registration Statement
- Annual Reports
- Family-Controlled Entities
- Gift and Estate Transfers
- Ohio Foreclosure Reform
- Director Compensation
- Board of Directors
- Director Independence
- Cyber Insurance
- Data Breach
- Lenders
- Receivership Statute
- Regulation A
- Regulation D
- Total Shareholder Return
- Compensation Committee Certification
- CDEs
- CDFI Fund
- Community Development Entities
- Community Development Financial Institutions Fund
- Government Shutdown
- New Markets Tax Credit
- NMTC
- NMTC Financing
- Regulation Fair Disclosure
- Social Media
- Benefits
- Healthcare Reform
- Litigation
- Marketing
- Public Company Transition Rules
- Employment Incentives
- HIRE Act
- Social Security Tax
- Tax Credit
Recent Posts
- Fifth Circuit Nixes Nasdaq Board Diversity Rules
- Corporate Transparency Act Update: Texas Federal Court Issues Nationwide Injunction
- SEC Fines Four Companies $7M for Violating Cyber Disclosure Rules
- FinCEN Issues Additional Guidance for Reporting Companies on Dissolved Entities
- Division of Corporation Finance Director Statement: The State of Disclosure Review
- FinCEN Issues Additional Guidance for HOAs and Trusts under the Corporate Transparency Act
- SEC Wins ‘Shadow Insider Trading’ Trial
- SEC Voluntarily Stays Climate Rules
- New SEC Climate Disclosure Rules – Temporarily Stayed
- Corporate Transparency Act Ruled Unconstitutional