By: William L. Bricker, Jr. and John Bricker
Effective January 1, 2024, FinCEN began accepting beneficial ownership information reports (“BOIRs”) required of Reporting Company’s by the Corporate Transparency Act, as discussed in our previous post “Corporate Transparency Act Reporting Requirements”. The BOIR Report together with filing instructions can be found here.
As we previously noted, initial BOIRs are required to be filed by Reporting Company’s: (i) by January 1, 2025, for existing entities formed, or for existing foreign entities registered to do business, in the United States on or before January 1, 2024; (ii) within 90 days of formation, or foreign entity effective registration, in the United States for Reporting Company’s formed or effectively registered on or after January 1, 2024, and before January 1, 2025; and (iii) within 30 days of formation, or foreign entity effective registration, in the United States for Reporting Company’s formed, or effectively registered, after January 1, 2025.
In addition, updated BOIRs for Reporting Company’s are required to be filed within 30 days of any changes to the initial reported ownership information, or upon becoming aware of any inaccuracy in the initial BOIR.