Certain Corporate Transparency Act (CTA) reporting companies impacted by some of the recent 2024 hurricanes may now have automatic timing relief from their CTA filing obligations. For those CTA reporting companies whose CTA filing deadlines fall within a designated window of time (described below), and whose principal place of business is within both an area qualifying for FEMA assistance and an area qualifying for IRS tax filing relief associated with certain named hurricanes, additional time is now available for timely submission of the reporting company’s required CTA filings.   HOWEVER, with the exception of existing reporting companies impacted by Hurricane Milton, existing reporting companies created prior to January 1, 2024, that are or were in existence at any time in 2024 and

FinCEN has now definitively weighed in on the reporting obligations of dissolved entities. It issued new FAQs on September 10, 2024, clarifying that reporting companies may not use dissolution (or possibly merger activity) to avoid reporting their beneficial ownership information as required by the Corporate Transparency Act (“CTA”). FinCEN clarified that such reporting obligations already have accrued for all reporting companies in existence at any time in 2024, so that while the deadline for making such filings may remain prospective, the filing obligation is not contingent on the reporting company’s ongoing existence. Reporting companies that intend to dissolve (or presumably merge out of existence) should ensure that they file their initial beneficial ownership reports (BOIRs) with FinCEN prior to dissolving (or