In August 2024, we wrote about the Corporate Transparency Act (“CTA”), its applicability to Washington’s Community Associations (condominium associations and homeowners associations), and the reporting requirements that Community Associations should be aware of prior to December 31, 2024. We updated that article in October 2024, as the CTA became that source of an active and litigious session of governance in an effort to stop the requirements from applying to all entities. A link to our October article is here: https://brandtlawgroup.com/the-corporate-transparency-act-and-washington-homeowners-associations-and-condominium-associations/ .
While we suggested, at the time, that entities be prepared to file their Beneficial Ownership Reports by January 1, 2025, ultimately, that date was delayed by ongoing litigation and various court rulings, rendering the necessity to meet the January deadline moot. Following our update in October, we closely monitored the progress of the litigation that ensued regarding the CTA. There was back and forth on the issues that became dizzying to keep up with when nearly weekly we were seeing a new ruling that altered the terms of the CTA requirements. However, as of March 21, 2025, the Financial Crimes Enforcement Network (“FinCEN”), a bureau within the U.S. Department of Treasury tasked with accepting the Beneficial Ownership Reports in accordance with the CTA, has issued a final interim ruling that “domestic reporting companies” are exempt from the reporting requirements contained in the CTA. However, “foreign reporting companies” may still need to fulfill certain reporting obligations under the CTA.
At this time, while the reporting obligations for domestic entities has been overturned, we would advise all foreign entities to meet with their lawyer and/or accountant to fully analyze their obligations and the requirements under the CTA.
Recent Comments