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Government Relations & Public Policy

Beneficial Ownership Reporting Requirements Now in Effect

January 11, 2024

The Corporate Transparency Act (CTA) went into effect on Jan. 1, 2024.  The CTA applies to privately held and many non-profit entities, including corporations, limited liability companies, limited partnerships, business trusts and other similar entities that are created by the filing of a document with a secretary of state or similar governmental office.

Companies in existence prior to January 1, 2024, will have 12 months to report the relevant information to FinCEN. Companies formed on or after this date will have 90 days to comply, up from the 30-day compliance requirement included in the original rules.  

The CTA was passed by Congress in 2021 and is considered by many legal experts to be the widest-reaching federal business entity law ever enacted. ICSC opposed many of the provisions in the legislation as unduly burdensome. 

FinCEN estimates there are at least 32.6 million “reporting companies” (entities that meet the core definition of a “reporting company” and are not exempt) in existence. Some exceptions do exist. For example, exemptions are granted for businesses regulated by the Securities and Exchange Commission, utilities, financial institutions, pooled investment vehicles and IRC Section 501(c) tax-exempt non-profits. “Large operating companies” are also excluded if they have a physical street address in the United States, 21 or more full-time employees, and more than $5 million in annual U.S. gross receipts as reported on the prior year’s federal tax return.

ICSC encourages members who believe they will be impacted by this law to consult with their legal counsel directly.

The final rules can be found here and an FAQ document is available here.

For more information contact Moutray McLaren at mmclaren@icsc.com.