CLIENT ALERT: CORPORATE TRANSPARENCY ACT

This message is to provide you with an important legal update concerning the Corporate Transparency Act (the “CTA”) and related filing requirements. If you have already filed your initial Beneficial Ownership Interest (“BOI”) report, or one has been filed on your behalf, you may disregard this update.

On February 18th, a federal court in Texas lifted the last remaining preliminary injunction against the enforcement of the CTA. As a result, the filing requirements for companies imposed by the CTA are once again enforceable. The Department of the Treasury has announced that the filing deadline will be extended to March 21, 2025. Moving forward, all newly formed companies will have 30 days after their formation to submit their initial filing.

Conclusion

MacLean Holloway Doherty & Sheehan, P.C. is recommending that any company that has not yet done so complete its CTA filing by the new deadline. To summarize, the new filing deadlines are as follows:

  1. For reporting companies formed prior to 2024, the deadline to file an initial, updated, or corrected BOI report is now March 21, 2025.
  2. For reporting companies formed between September 3, 2024 and February 18, 2025 (i.e., companies formed while the injunction was in place, or would have otherwise had a filing due while the injunction was in place), the deadline to file an initial, updated, or corrected BOI report is also March 21, 2025.
  3. Reporting companies formed or registered on or after February 18, 2025, must file within 30 days from the date of creation or registration.
  4. Reporting companies previously provided with extended deadlines due to disaster relief should follow the later deadlines.

We are happy to assist you with any questions you may have about CTA and its reporting requirements or with filing. You can reach us Monday through Friday from 8:30 am to 5:30 pm at 978-774-7123.

To view our initial alert regarding CTA, including answers to frequently asked questions, please refer to the following page on our website: https://mhdpc.com/corporate-transparency-act-or-cta/

You will find additional Q&As, a compliance guide, a work sheet to determine if you qualify for an exemption, and other resources on FinCen’s dedicated CTA site:

https://www.fincen.gov/boi/small-entity-compliance-guide

This client alert is intended to inform you of legal developments which may affect your or your business. It is not intended to constitute legal advice with respect to any specific legal issue or question.  This client alert may constitute advertising under the rules of the Massachusetts Supreme Judicial Court.