Massive New Federal Reporting Requirements Will Start in 2024

Do you own 25% or more of a limited liability company, partnership, or other small entity that owns real estate or runs a small business (any of these, a "company")? Are you president, CEO, general counsel, or COO of a company? Even if you don't have that title, do you perform a similar role? Do you have "substantial control" over any company? 

If you answer yes to any of those questions, then starting in 2024 you will need to register, or be registered, in a new federal database. 

Each registration will need to include your name, date of birth, residential street address (a business address won't do), a driver's license or other ID number, and a photograph of the document substantiating that number. This information will mostly be collected online. 

If anyone registered in the database moves to a new residence, the new address must be reported within 30 days. 

Any company that already exists as of January 1, 2024 will need to register by the end of that year. Companies newly created on or after January 1, 2024 will need to register within 30 days after creation.

Special registration requirements apply for anyone who files the paperwork necessary to create companies. It remains to be seen whether those requirements will lead law firms to stop handling that work. 

This document is designed for general information only. The information presented in this document should not be construed to be formal legal or tax advice nor the formation of a lawyer/client relationship. 

For more information on this and other topics, please contact Kevin via any of the channels listed below:

📧 kevin@kmckernan.com 📞 718-317-500