Companies hoping to avoid beneficial owner reporting requirements under the Corporate Transparency Act (CTA) by dissolving or merging entities out of existence got some bad news recently. On July 8, 2024, FinCEN announced that only companies dissolved prior to January 1, 2024, would not have to file BOI reports--and that companies dissolved after January 1, 2024, must still file a BOI report even if they no longer exist. Entities merged out of existence will likely need to adhere to the same rules. 

While there have been legal challenges brought against the CTA, companies formed prior to 2024 must still comply with the reporting requirements by the end of the year. Companies formed during 2024 must file their BOI report within 90 days of formation.