With the implementation of the Corporate Transparency Act, many businesses are required to report Beneficial Ownership Information (BOI) to the Financial Crimes Enforcement Network (FinCEN). Here, we answer some of the most frequently asked questions to help you navigate these new requirements.
What is Beneficial Ownership Information Reporting?
Beneficial Ownership Information (BOI) reporting involves providing detailed information about the individuals who own or control a company. This information is submitted to FinCEN to enhance transparency and prevent financial crimes.
Who Needs to Report BOI?
If you operate a "reporting company," you are required to submit BOI. A reporting company includes certain types of U.S. and foreign entities doing business in the U.S. Entities.
What Information Must Be Reported?
For reporting companies:
Full legal name
Trade names (if any)
Current U.S. address
Jurisdiction of formation
IRS Taxpayer Identification Number (TIN)/Employer Identification Number (EIN)
For beneficial owners and company applicants:
Full legal name
Date of birth
Current address
Unique identifying number from a non-expired document (e.g., passport, driver’s license)
Image of the document containing the unique identifying number
When Should BOI Be Reported?
Starting January 1, 2024, FinCEN will accept BOI reports electronically.
Existing companies as of January 1, 2024, must file by January 1, 2025.
New companies (before January 1, 2025) must file within 90 days of creation or registration.
New companies (after January 1, 2025) must file within 30 days of creation or registration.
Updates and corrections to previously submitted BOI must be filed within 30 days of the change or discovery of inaccuracies.
How to Report BOI?
Reporting companies can submit BOI electronically through the BOI E-Filing portal at https://boiefiling.fincen.gov starting January 1, 2024. There are two methods:
Upload a finalized PDF version of the BOI Report (BOIR).
Fill out and submit the web-based version of the BOIR.
Tips for Successful Filings
Complete all required fields: Ensure every mandatory field, marked with an asterisk (*), is filled.
Provide accurate address formats: Enter ZIP Codes and foreign postal codes without spaces or special characters.
Include clear document images: Attach readable images of identification documents, ensuring they are no larger than 4 MB.
Avoid prohibited terms: Do not use terms like AKA, DBA, NMN, NONE, etc., in the text fields.
Common Scenarios
Initial Report: If this is your first BOIR, check the "Initial report" box.
Updates and Corrections: For updates, select "Update prior report"; for corrections, select "Correct prior report".
Newly Exempt Entities: If your company becomes exempt after a previous filing, select "Newly exempt entity".
For further details, always refer to FinCEN’s Small Entity Compliance Guide and the official FinCEN website.
If you have more questions about BOI reporting or need assistance with your filings, feel free to reach out! As your trusted tax strategist, I'm here to help you navigate these new requirements smoothly.