Back to News

Corporate Transparency Act Update: Dissolved Entities May Still Need to File Beneficial Ownership Reports 

Published on

July 9, 2024

UPDATE: On March 21, 2025, the Financial Crimes Enforcement Network issued an Interim Final Rule removing Beneficial Ownership Information Reporting requirements for U.S. companies and U.S. individuals under the Corporate Transparency Act. For more details, please view our latest alert here.

On January 1, 2021, Congress enacted the Corporate Transparency Act (the “CTA”), which requires that certain companies disclose the identity of their beneficial owners and provide other information to the Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) through Beneficial Ownership Information Reports (“BOIRs”) beginning January 1, 2024. For a quick overview, you can read about the basics of the CTA and what you need to know about its implementation here.

FinCEN has previously advised that all “reporting companies” formed prior to January 1, 2024, will have a January 1, 2025 deadline to file BOIRs. Reporting companies formed during the 2024 calendar year must file their BOIRs within 90 days of their formation. Any entity formed on or after January 1, 2025 which is classified as a reporting company must file their BOIRs within 30 days of their formation. 

Yesterday, FinCEN released updated FAQs pertaining to entities which are in existence on or after January 1, 2024, but are dissolved prior to their filing deadline. The FAQs state that any entity which is a reporting company must file a BOIR prior to the reporting company’s filing deadline, regardless of whether the entity has been dissolved before the date of its filing deadline. 

These newly released FAQs mean that a reporting company which existed as of January 1, 2024 must make a BOIR filing even if it is dissolved prior to January 1, 2025 – its deadline to file. Furthermore, entities which qualify as reporting companies and are formed in 2024, and which have been dissolved prior to their 90th day of existence, are still required to file their BOIRs within the first 90 days of existence, regardless of whether the reporting company has been dissolved before its 90-day filing deadline. Reporting companies formed in 2025 or later will be required to file BOIRs within 30 days of the date of formation, regardless of whether the reporting company has been dissolved before its 30-day filing deadline. 

The attorneys at Barley Snyder continue to follow the Corporate Transparency Act closely and provide updates as new information is released. If you have any questions regarding the CTA or the beneficial ownership disclosure requirements, please contact partner Dan Desmond, attorney Charmaine Nyman or any member of the Barley Snyder Business Practice Group. You may also visit our Corporate Transparency Act Response Team webpage for more information. 


Related News

View More News
Press Release
August 21, 2025

Barley Snyder Attorneys Recognized by Best Lawyers in America

For Immediate Release Lancaster, Pa. – Barley Snyder is proud to announce that 51 of its attorneys have been recognized by...

Learn More
News Alert
August 20, 2025

One Big Beautiful Bill: Key Tax Provisions Impacting Businesses

On July 4, 2025, President Donald Trump signed into law legislation (H.R.1), known as the One Big Beautiful Bill Act (the ...

Learn More
News Alert
August 15, 2025

Commonwealth Court Reaffirms Need for Municipalities and Courts to Adhere to the Environmental Rights Amendment

On August 13, 2025, the Pennsylvania Commonwealth Court reaffirmed that local municipalities and courts have an obligation to...

Learn More

Other Upcoming Events

View All Upcoming Events
Oct
07
2:30 pm
-
6:00 pm
event
Location

2025 York Business Seminar

Learn More
Nov
12
2:30 pm
-
6:00 pm
event
Location

2025 Reading Business Seminar

Learn More
Oct
14
2:30 pm
-
6:00 pm
event
Location

2025 Harrisburg Business Seminar

Learn More

Get in Touch

Our attorneys, paralegals and staff look forward to hearing from you. Please reach out to let us know how we can help.

Get In Touch
RECOGNIZED IN
Super Lawyers
Best Law Firms US News
Best Lawyers