New FinCEN Guidance on Reporting Requirements: What You Need to Know
The Financial Crimes Enforcement Network (FinCEN) recently issued crucial new guidance on the reporting requirements for companies under the Corporate Transparency Act (CTA). This update specifically addresses what happens when a Reporting Company dissolves or terminates before its initial Beneficial Ownership Information Report (BOIR) is due.
In short, FinCEN now mandates that even if a company dissolves or terminates before the filing deadline, it still must file an initial BOIR. However, once this initial report is filed, the company does not need to submit an updated report to document its dissolution or termination.
This guidance affects:
Companies formed or registered before January 1, 2024, that dissolved or terminated before the January 1, 2025 deadline.
Companies formed or registered in 2024 that dissolved or terminated within 90 days of their formation, including those created for temporary mergers.
This clarification helps streamline the reporting process and ensures compliance even in cases of early termination or dissolution.
For more detailed information, please refer to the full article on Holland & Knight's website.