Compliance Stuff

Effective January 1, 2026, New York’s LLC Transparency Act imposing beneficial ownership reporting on New York LLCs and foreign LLCs authorized to do business in New York goes into effect. Despite the interim final rule (IFR) issued by the Financial Crimes Enforcement Network (FinCEN) in March 2025 revising the definition of “reporting company” for purposes of the federal Corporate Transparency Act (CTA) exempting entities formed under the laws of a U.S. state or tribal authority from reporting under the CTA, the New York Limited Liability Company Transparency Act (NYLLCTA) survives and will go into effect on January 1, 2026 . The NYLLCTA applies to both limited liability companies (LLC) formed in the state of New York or LLCs formed in any other state (foreign LLCs) that are registered to do business in the state of New York. As a result, LLCs formed under New York law or registered to do business in New York (each a “reporting company) must file either the required beneficial ownersh...

Filings Due January 1, 2025 In October 2023, we warned our readers of a new nightmare – beneficial ownership information ( BOI ) reporting under the Corporate Transparency Act ( CTA ). (Original article can be found  here .) As the January 1, 2025 filing deadline approaches for entities formed before this year, we wanted to give you the benefit of our experience with preparing and filing BOI reports. Over the past 12 months we got our own unique identifier numbers (more on that below) from the Treasury’s Financial Crimes Enforcement Network ( FinCEN  website); delved into plenty of organizational charts; and helped clients file many BOI reports. We discovered that the FinCEN web site ( https://fincen.gov/boi ) works well and is simple to navigate. From the landing page, you can link to FinCEN’s FAQs (which are always being expanded) and educational materials; the application for a unique identifier number; or the portal for filing the actual BOI report. But we have heard from ...