Corporate Transparency Act: Entities Formed in Early January Must Comply with the CTA as Early as Today

• 4.1.2024

By: Samuel Goldsmith and C. S. Avery Reaves

As we have previously reported, under the Corporate Transparency Act (“CTA”), a reporting company that is formed or initially registered to do business in 2024 must file its initial beneficial ownership information reports (“BOI Reports”) within 90 calendar days of the earlier of (a) the date the reporting company receives notice of its creation or registration or (b) the date a secretary of state or similar office provides public notice that the reporting company has been created or registered. Because nearly all offices of secretaries of state were closed on New Year’s Day, the earliest date that a reporting company created or registered in 2024 could have triggered its 90-day filing obligation in most jurisdictions was January 2, 2024. 90 calendar days from January 2 brings us to today (Monday, April 1). 

For all reporting companies that were formed or registered in early January 2024 (other than those who are named plaintiffs in National Small Business United v. Yellen), this is your reminder that your deadline to file your initial BOI Report is fast-approaching if it has not already arrived. Reporting companies formed or registered prior to January 1, 2024, have until January 1, 2025, to file their initial BOI Reports.