NEW FEDERAL REPORTING LAW TAKES EFFECT

In 2021, Congress passed the Corporate Transparency Act (CTA) which created a new reporting requirement for many businesses as part of the U.S. government’s effort to crack down on money laundering, corruption, tax evasion, and other crimes. The Financial Crimes Enforcement Network (FinCEN), which is part of the U.S. Department of Treasury, is the government agency administering the program. The CTA requires small and independent businesses to file what is termed “beneficial ownership information” with FinCEN. Businesses impacted are corporations, limited liability companies (LLCs) and other similar entities that are created by filing with a secretary of state, and have:

• 20 or fewer full-time employees
• Filed federal income taxes in previous year demonstrating $5 million or less in gross receipts or sales; and
• Do not qualify as an exempted entity under the law

There are 23 exempted entities under the law, which include publicly traded companies, nonprofits, financial and insurance companies, public utilities and subsidiaries of exempt entities.

Businesses must report information on the company itself, its beneficial owners, and the applicant who files the report. Company information to be reported includes:

• Legal name
• Any DBA or other trade name
• Address of its principal place of business
• The jurisdiction of its formation/registration
• Taxpayer ID Number

A beneficial owner is any individual who exercises substantial control over the company or who owns or controls at least 25% of the company. Beneficial owner information to be reported includes:

• Individual’s name
• Date of birth
• Residential address
• An identifying number from a driver’s license, passport, or other approved document (including an image of the document)

Applicant information to be reported is the same as the beneficial owner information.

Businesses formed prior to January 1, 2024 have until January 1, 2025 to file the initial report. A business formed in 2024 has 90 days after receiving notice of its creation to file an initial report, and a business formed in 2025 and thereafter has 30 days after receiving its notice of creation to file. There is no fee to file,

Detailed information on the law and the e-filing system can be accessed at fincen.gov/boi.

AAM MEMBERSHIP & THE IMPORTANCE OF YOUR PAC CONTRIBUTION

We need your help to maintain our strong voice for the multifamily rental property industry. It starts with membership. Membership supports our staffing and lobbying efforts, as well as communications, education, and member benefits. For just $1.80 per unit (minimum dues $250), multifamily rental property owners can support the organization that tells your story in Lansing. Associate members (suppliers or service organizations) can join for $495 annually. If you are not currently a member, we strongly urge you to join today online BY PRESSING HERE. If you have questions about member benefits, contact AAM at 248-737-4477.

Just as important as membership, the Apartment Association of Michigan Political Action Committee (AAM-PAC) needs your support. AAM-PAC accepts contributions from members and aggregates them into one fund, which then financially supports those elected officials who understand the important role of rental housing in Michigan’s economy. You must be an AAM or HBA Member to contribute to the fund, which has a fundraising goal of $150,000 for 2023-24. Remember, an AAM-PAC contribution must be made via personal, partnership, LLP, or LLC check or credit card. Members - make your PAC Contribution online BY PRESSING HERE.