Taxes & Ultimate Beneficiary: new reporting requirements

According to the Corporate Transparency Act (CTA), "reporting firms" must submit a report to the Financial Crimes Enforcement Network (FinCEN) of the Department of Treasury that includes details about the applicants and beneficial owners of the company. The data gathered will be retained in a secure database managed by FinCEN, to which only federal agencies, state agencies that have a court order, and financial institutions that have the company's approval would have access.

On September 29, 2022, FinCEN issued a final rule implementing the beneficial ownership (BOI) reporting requirements. The rule describes who must file a BOI report, what information must be reported, and when a report is due. The effective date for the final rule is January 1, 2024.

The information must be provided about the reporting company, its beneficial owners, and its company applicants.