Corporate Transparency Act (CTA)

The Corporate Transparency Act (CTA) took effect on January 1, 2024.

CTA requires most entities registered with a Secretary of State (including LLCs, corporations, and limited partnerships) to register with the Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) to disclose information regarding the people who:

• hold direct or indirect substantial control (including but not necessarily limited to a formal management position); or
• hold direct or indirect ownership of 25% or more in the entity (collectively called "beneficial ownership" by FinCEN), and then to keep that registration updated going forward. The penalties for failing to comply are significant.

While you can file CTA FinCEN reports on your own, determining the required disclosures may be complex if you own your interests through trusts and other structures; we are available to assist you with this.

As well, if privacy is important to you, it is critical that you obtain a “FinCEN Identifier” which will eliminate the need for you to disclose your personal information (including residential address and copies of photo ID) directly to the people filing CTA reports for those companies.
 

Your CTA obligations

Please note that we are unable to advise you on the impact of the CTA without being specifically instructed and engaged to undertake an assessment on your behalf. 

If you own or have substantial control of one or more entities, own them through trusts or other complex structures, or are concerned about preserving your privacy, please contact us right away to discuss your CTA planning.

More information is available on our Corporate Transparency Act page linked below and more information from the government is available here. 

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