Key Date for CTA Reporting Obligations

The Corporate Transparency Act (CTA) requires certain companies to report beneficial ownership information to FinCEN. The key date for determining if a company has to report is January 1, 2024.

Reporting Requirement for Existing Companies

Reporting entities created or registered to do business in the U.S. prior to January 1, 2024 must file a report with FinCEN by January 1, 2025.

No Exception for Short-Term Companies

The CTA reporting requirement applies to companies active on or before January 1, 2024.

There is no exception for companies that dissolve shortly after the January 1, 2024 date.

Example Company Dissolved January 2, 2024

So even though a hypothetical company dissolved on January 2, 2024, it was still active on the key date of January 1, 2024.

Therefore, it would still need to file a report with FinCEN by the deadline of January 1, 2025.

The dissolution two days later does not relieve it of that reporting obligation.

Summary

In summary, yes a company that dissolved shortly after January 1, 2024 would still need to register with FinCEN under the Corporate Transparency Act. The requirement is based on being active on January 1, 2024 itself, not ongoing activity afterwards.

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Also See

2024’s New Corporate Transparency Law: What Every Business Must Know