CTA for Small Businesses: What Information to Report

With the Corporate Transparency Act set to take effect on 1/1/2024, many small companies are wondering how to proceed.  We have published several items already about what companies are covered, how to determine who your “beneficial owners” (BOs) are, and what companies are exempt from reporting (among other topics). Once you have determined that your business is a “reporting company,” does not qualify for an exemption, and who your BOs are, what information will the CTA require from you?  

Fortunately, the answers to this question are (fairly) simple. Reporting companies must report identifying and contact details in three categories: for the company itself, for its BOs, and for the “company applicant(s)” for any companies formed starting 1/1/2024 (we will discuss “company applicant” in detail in a later posting, but essentially this is the person(s) who made or oversaw the filing that formed the company).  Below is a summary of what must be reported for each of these three persons or entities.

REPORTING COMPANY

• Full legal name
• All trade names (DBAs)
• Current US address
• Jurisdiction where formed (or first qualified, if a foreign company)
• Taxpayer ID number

EACH BENEFICIAL OWNER and COMPANY APPLICANT (if required) 

• Full name
• Date of birth
• Residential address (business address for certain company applicants)
• Unique number, issuing jurisdiction, and image of current identifying document (passport, driver's license, certain other government-issued IDs)

Note that future changes to information about the company or its BOs may require filing an updated report that captures such changes. For example, if a BO sells their stake in the company, or receives a new passport, such details must be reported in an updated filing.  Changes in company applicant information do not have to be reported.  

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