Listen to this post

The Corporate Transparency Act (the “CTA”) will become effective on January 1, 2024.  Entities in existence prior to that date that would otherwise obligated to make filings with the United States Department of the Treasury Financial Crimes Enforcement Network (“FinCEN”) have until January 1, 2025 to comply.  However, entities formed after January 1, 2024 had a much shorter compliance period.  Under the original regulations promulgated on September 30, 2022, newly formed entities would have only 30 days following “notice of their creation or registration” to comply with the filing requirements.  FinCEN published a notice of proposed rulemaking on September 28, 2023 and the final regulations were just promulgated on November 30, 2023 that would extend the initial filing period to 90 days. The new rule, along with the CTA, becomes effective on January 1, 2024.  As a result, an entity formed on or after January 1, 2024 but prior to January 1, 2025 that is otherwise obligated to file under the CTA has up to 90 days to comply with the initial filing requirements.  Entities formed after January 1, 2025 continue to be subject to the 30-day filing requirement.

The CTA, 31 U.S.C. 5336, can be accessed here: https://www.fincen.gov/sites/default/files/shared/Corporate_Transparency_Act.pdf

Regulations under the CTA, 31 CFR 1010.380, can be accessed here:

https://www.fincen.gov/sites/default/files/shared/31_CFR_1010_380_excerpt_from_Final_Rule.pdf

Final rule extending the initial reporting period can be accessed here:

https://www.govinfo.gov/content/pkg/FR-2023-11-30/pdf/2023-26064.pdf

Reach out to Liskow attorneys Marilyn MaloneyLeon Rittenberg, and Julie Chauvin for further information regarding the Corporate Transparency Act, and visit our resource page here.

Disclaimer: This Blog/Web Site is made available by the law firm of Liskow & Lewis, APLC (“Liskow & Lewis”) and the individual Liskow & Lewis lawyers posting to this site for educational purposes and to give you general information and a general understanding of the law only, not to provide specific legal advice as to an identified problem or issue. By using this blog site you understand and acknowledge that there is no attorney-client relationship formed between you and Liskow & Lewis and/or the individual Liskow & Lewis lawyers posting to this site by virtue of your using this site. The Blog/Web Site should not be used as a substitute for legal advice from a licensed professional attorney in your state regarding a particular matter.

Privacy Policy: By subscribing to Liskow & Lewis’ E-Communications, you will receive articles and blogs with insight and analysis of legal issues that may impact your industry. Communications include firm news, insights, and events. To receive information from Liskow & Lewis, your information will be kept in a secured contact database. If at any time you would like to unsubscribe, please use the SafeUnsubscribe® link located at the bottom of every email that you receive.

Print:
Email this postTweet this postLike this postShare this post on LinkedIn
Photo of Marilyn C. Maloney Marilyn C. Maloney

Marilyn Maloney is a Houston-based business lawyer helping clients with commercial lending, energy deals, real estate, intellectual property, mergers and acquisitions, corporate trust and other commercial transactions. Marilyn, who was founding chair of the firm’s Houston office, has years of experience throughout Texas…

Marilyn Maloney is a Houston-based business lawyer helping clients with commercial lending, energy deals, real estate, intellectual property, mergers and acquisitions, corporate trust and other commercial transactions. Marilyn, who was founding chair of the firm’s Houston office, has years of experience throughout Texas, Louisiana, the region and the U.S.

Photo of Leon H. Rittenberg III Leon H. Rittenberg III

Leon Rittenberg III is a New Orleans native. His practice focuses on serving the needs of small and mid-sized businesses and their owners; including philanthropy and non-profit law, taxation, finance, private equity, estate planning, probate, real estate, mergers and acquisitions and related matters.

Leon Rittenberg III is a New Orleans native. His practice focuses on serving the needs of small and mid-sized businesses and their owners; including philanthropy and non-profit law, taxation, finance, private equity, estate planning, probate, real estate, mergers and acquisitions and related matters. Leon represents the interests of a number of private investors, oil service businesses, marine transportation companies and physician groups. He is a Board Certified Tax Specialist and Board Certified Estate Planning & Administration Specialist, as certified by the Louisiana Board of Legal Specialization. He frequently lectures in areas such as taxation, estate planning and maritime transactions.

Leon is a Fellow of the American College of Tax Counsel. He has been recognized by Chambers USA (Louisiana Marine Finance – 2021; Louisiana Corporate/M&A: Tax section – 2017), Louisiana Super Lawyers (Tax, Estate Planning & Probate and Business/Corporate), and the Best Lawyers in America (Non-Profit/Charities Law and Trusts & Estates) since 2007, and by New Orleans Magazine as one of their “Top Lawyers of New Orleans” for his work in Equipment Finance Law, Mergers & Acquisitions Law and Tax Law. New Orleans City Business selected him for their Leadership in Law class of 2014, which “identifies and honors 50 outstanding legal professionals whose successes in law and contributions to the community have set the pace for the legal community.”

Photo of Julie Chauvin Julie Chauvin

Julie Chauvin practices in the areas of estate planning, real estate and business transactions.

In her estate planning practice, Julie advises clients, including business owners and high net worth individuals, on wills, trusts, marital agreements and other estate planning matters. Julie also works

Julie Chauvin practices in the areas of estate planning, real estate and business transactions.

In her estate planning practice, Julie advises clients, including business owners and high net worth individuals, on wills, trusts, marital agreements and other estate planning matters. Julie also works with family members and executors or administrators on succession matters and assists litigation attorneys in succession and fiduciary litigation.

Julie represents owners, developers, and lenders in the acquisition, leasing, financing, and development of commercial real estate. Julie issues title insurance on behalf of lenders and owners as a licensed title insurance agent for Liskow’s title agency, Lewis Title Co., Inc.

As a business attorney, Julie represents clients on both sides of transactions, including walking clients through due diligence and handling contract negotiations. She also regularly advises clients on corporate and LLC governance matters and prepares purchase agreements, employment agreements, and entity formation and governance documents. Julie has also assisted local banks on commercial loan transactions.

Julie has been recognized as a top lawyer in The Best Lawyers in America and Acadiana Profile magazine.

Julie serves on the Firm’s Board of Directors, Strategic Planning Committee and Pension Committee, and is the Head of Office Administration for the Firm’s Lafayette office.