As we have done in prior years, we are providing a high-level checklist that covers many common questions and issues that we plan to tackle with clients this year. This list both highlights pragmatic items typically covered at year-end and reflects on annual best practices and considerations. These points are always supplemented by the distinct and specific challenges and opportunities for each of our clients. We look forward to discussing these matters with you—as well as any other topics you deem important—in the weeks and months ahead.
We want to draw particular attention to the first item on the checklist, dealing with the Corporate Transparency Act, because the reporting deadline of December 31, 2024, is fast approaching. The Corporate Transparency Act (CTA)1 is a sweeping new law that requires the disclosure of ownership of corporations, limited liability companies, and similar entities, and it will affect tens of millions of entities, including most of the business entities our clients have formed for estate planning, property ownership, asset protection, and similar purposes. While the intent of the legislation is to combat illicit activity like money laundering and financing of terrorist organizations, the CTA applies equally to private companies involved in legitimate and customary activities. Companies falling under this regulation must submit Beneficial Ownership Information (BOI) Reports to the Treasury’s Financial Crimes Enforcement Network (FinCEN). These reports provide basic legal information about the company itself, the entity’s owners, and the individuals that create or register the entity. The deadlines are as follows:
- All companies formed prior to 2024 must file a report by December 31, 2024.
- Companies formed during 2024 must file a report within 90 days of formation.
We anticipate the FinCEN systems may be overloaded at year-end if, as expected, many companies delay reporting until the last moment. Legal advisors may also be overwhelmed by last-minute requests for assistance. Accordingly, we strongly encourage clients to begin the process well ahead of December. The Strategic Advisory team is available to help clients identify entities that may be subject to reporting requirements and to coordinate the reporting process with clients’ attorneys or other advisors. 
Annual Planning Checklist
This high-level checklist covers many common questions and issues that we plan to tackle with clients. This list both highlights pragmatic items typically covered at year-end and reflects on annual best practices and considerations. We hope you find it useful.
Download your copy of the Annual Planning Checklist
1Corporate Transparency Act (CTA) information can also be found here.
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