Lisa and the Law

Dissolved Businesses STILL have to comply with the CTA

Any business that has not been formally, irrevocably and permanently dissolved as of January 1, 2024 may still have to file a Beneficial Ownership Information Report (BOIR) unless it is otherwise exempt. Many businesses that are inactive MAY not meet the six (6) specific requirements to be exempt under the inactive entity exemption. Primarily, businesses must have been formed PRIOR to January 1, 2020 or they will not meet the requirements of the exemption. Businesses exempt from filing a BOIR under the inactive entity exemption must also, hold no assets (no bank accounts), no foreign ownership, no change in ownership in last 12 months, not actively operating and no transactions over $1,000 in last 12 months.

Under this new FinCEN guidance, once a dissolved entity has filed a BOIR there are no further reporting requirements and no additional report must be filed to state that the entity was dissolved. In addition, any entity formed in 2024 that dissolves before its initial BOIR deadline after its formation must still file a BOIR.

Related Services: CTA Compliance