Beneficial Ownership Information Reporting

• tax-exempt entities;
• sole proprietorships, trusts, and general partnerships that are not registered with a Secretary of State;
• an entity with (a) more than 20 full-time employees; (b) an operating presence at a physical office within the U.S.; and (c) more than $5,000,000 of US-sourced gross receipts reported on its prior year federal income tax return; and
• other very limited exemptions may apply. 

 Under the CTA, most entities formed in the U.S. are required to submit certain details of:

• any individual who directly or indirectly owns or controls at least 25% of the ownership interest in a reporting entity; or
• any individual who exercises substantial control over the day-to-day business affairs of the reporting entity. 

After filing the initial report, the reporting entity is required to file updates to such report upon changes to the information provided for a reporting entity or its beneficial owners.  Such updated report must be filed within thirty (30) days of such change.