Corporate Transparency Act (CTA) and Beneficial Ownership Information (BOI) Requirements
The Corporate Transparency Act (CTA) went into effect Jan. 1, 2024. The Act requires that legal entities formed and operated in the United States provide identifying information (including the name, birthdate, physical address and a photo from a driver’s license or passport) for each beneficial owner or person with control. The information will go into a national registry controlled by FinCEN, a bureau of the U.S. Department of Treasury, and will be available to law enforcement agencies for their use in detecting illegal activity. State Bar General Counsel Paula Frederick previewed the Act in her October 2023 Georgia Bar Journal article, “Transparency Is Coming.”
Please note that the original Dec. 31, 2024, filing deadline for entities already in existence by Jan. 1, 2024, has been suspended by the U.S. District Court of the Eastern District of Texas, which granted an injunction on Dec. 3 temporarily blocking the CTA nationwide. (Reporting companies are not currently required to file beneficial
ownership information with FinCEN and are not subject to liability if
they fail to do so while the order remains in force. However, reporting
companies may continue to voluntarily submit beneficial ownership
information reports.)