Reporting Requirements for Private Practitioners related to the Corporate Transparency Act

We want to call attention to new reporting requirements for private practitioners with LLCs and similar entities - with deadline of Jan. 1, 2025 for filing.

National NASW has posted about this, and we are sharing that information directly from the chapter, to help ensure that affected members are aware.

These are called Beneficial Ownership Information (BOI) reports, as required by the Federal Corporate Transparency Act (CTA).

See below for recent National NASW posting about this, which includes a link to a previous article with full information.

Here are some key takeaways from the original NASW posting on this.

The CTA applies to corporations, limited liability companies (e.g., LLCs, PLLCs), and other entities that are created through filing a document with a secretary of state (e.g., LLPs, LLLPs, and business trusts) and the beneficial owners of those entities.  Beneficial owners are individuals who exercise substantial control over a reporting company or control at least 25% of the ownership interests of a reporting company.

If you directly or indirectly have a significant ownership stake or control in a reporting company, you must file a report with your BOI to FinCEN. FinCEN information is accessible to federal, state, local, and tribal officials, and certain foreign officials who submit a request for BOI through a U.S. federal government agency in connection with national security, intelligence, and law enforcement. The information will be stored in a non-public database.

The deadline to report BOI depends on the date of company formation:

• Companies created before January 1, 2024, must file BOI by January 1, 2025.
• Companies created on or after January 1, 2024, must file BOI within 90 calendar days of receiving notice of the company’s registration.
• Companies created on or after January 1, 2025, must file BOI within 30 calendar days of receiving notice of the company’s registration.

NASW members are welcome to contact NASW Member Services to seek a legal consultation on this and other social work practice legal issues.

Note: You may need to consult an accounting and/or tax professional for compliance questions or to prepare for tax year requirements.

See below for information on this through the Massachusetts Secretary of State office.

The link to the e-filing system is below, and includes information and instructions as needed. It seems like it will be relatively straightforward.

We realize that this notice comes close to the deadline for filing. We hope that many will have heard of this through National NASW or otherwise, and that this information will be helpful in moving forward at this time.