Does anyone know if the new Corporate Transparency Act reporting requirement applies to an LLC that was formed years ago for the purposes of ownership of NFA items?  I’ve read the requirements posted by the government and having to file by January 25, 2024 or face criminal and civil penalties. It is very confusing on determining if an LLC that does not generate income but has assets would be exempt. I’ve searched forums on NFA items and this subject has not been raised so I suspect no one - like me - was aware of this.
Any lawyers able to weigh in?

If you are talking about the FinCEN BOI then my understanding is that if your LLC is not in one of the exempt business categories then it must file.  
https://www.fincen.gov/boi/small-entity-compliance-guide

yes it has to file, income and/or assets dont matter at all.  ETA - this isnt exactly right; there is an exemption for certain entities deemed "inactive" but one of the requirements is that it has no assets, as in zero.  see exemption #23 in the linked handout

https://www.fincen.gov/boi/small-entity-compliance-guide

but you have all of 2024 to file for existing entities, the deadline isnt in january

this would be a good time to chat with the lawyer who created it for you

I did some more digging on it.  Failing to file an existing business by 12/31/2024 includes steep fines and potential federal charges with up to two years of jail time.

https://www.mondaq.com/unitedstates/corporate-and-company-law/1404484/fincen-updates-frequently-asked-questions-on-beneficial-ownership-reporting-rule-ahead-of-jan-1-2024-effective-date

IANA lawyer but I do hold an FFL/SOT.  My personal opinion - I would transfer the NFA out of the LLC to a trust and shut down the LLC.  Yes I know it costs $200 a pop but a trust is a lot more private and you have no idea what FINCEN will do with all that data or who will FOIA it.

has anyone filed yet ?

It has been ruled unconstitutional as of now.  It is supposed to be appealed.

https://www.forbes.com/sites/matthewerskine/2024/03/04/corporate-transparency-act-ruled-unconstitutional-by-federal-district-court/?sh=4cf0876f1d47

but the ruling only applies to parties in that case, so far.

Complete and utter bullshit. There is a half-hour inservice I need to watch.

Accountants are exempt...but not lawyer. We are heavily regulated enough already.

Eta for catastrophic spelling from phone posting.

Thanks, I missed that part while skimming the article.

Hopefully it gets tossed for all of us.