As described in our earlier alert on the implementation of the Corporate Transparency Act, FinCEN's new beneficial ownership reporting rules will go into effect on January 1, 2024. In its final rule adopted on September 30, 2022, FinCEN required companies created or registered on or after January 1, 2024 to file a beneficial ownership information report within 30 days of receiving notice of their creation or registration, unless they are exempt. Reporting companies created or registered prior to January 1, 2024 have until January 1, 2025 to file their reports, unless they are exempt.
On November 29, 2023, FinCEN extended this filing deadline from 30 days to 90 days for reporting companies created or registered during 2024. This extension is being provided to give those companies more time to become familiar with FinCEN's guidance and educational materials on the new beneficial ownership reporting requirements.
Reporting companies created or registered before January 1, 2024 will continue to have until January 1, 2025 to file their initial reports with FinCEN.
Reporting companies created or registered on or after January 1, 2025 will continue to have 30 days to file their initial reports with FinCEN.
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