July 10, 2024

7-8-2024 Corporate Transparency Act Update

On July 8, 2024, FinCEN released new FAQs confirming that unless an entity was formally and irrevocably dissolved under state law prior to 1/1/2024, it is subject to the beneficial owner reporting requirements. This is true for entities existing on 1/1/2024 or formed in 2024 and which dissolve before the initial 1/1/2025 reporting deadline. While such entities must file their initial report, there is no requirement to file an additional report that the entity has ceased to exist. See FAQs C12, C13, and C14, available at https://www.fincen.gov/boi-faqs#B_3.

We are prepared to help your company navigate the reporting obligations of the CTA. If you have any questions, please reach out to Kate Polozie, Esq (585) 987-2910 or kpolozie@woodsoviatt.com or, for tax-exempt organizations, Danielle Ridgely, Esq. (585) 987-2914 or dridgely@woodsoviatt.com , or another member of the Business and Tax Department at Woods Oviatt Gilman LLP.