Beneficial Ownership Information (BOI) Reporting

Starting in 2024, the Corporate Transparency Act ("CTA") mandated certain entities (primarily small and medium-sized businesses) created in or registered to do business in the United States to report information about their beneficial owners — the individuals who ultimately own or control a company — to the Financial Crimes Enforcement Network ("FinCEN"). If your individual return includes a business, you are responsible for compliance with the CTA, if applicable, and for ensuring that any required reporting of beneficial ownership information (including the initial filing and any required ongoing updates and/or corrected reports that may be necessary) is timely filed with FinCEN as required by the CTA. Our firm’s services under the terms of this agreement do NOT include any advising, consulting, or submission of any required reporting related to your compliance with the CTA.

Individual taxpayers, trusts, and general partnerships are exempt from this reporting; however, single-member LLCs (among their companies) fall under the reporting category as entities created by filing organizational papers with the Secretary of State's Office.

Note that on March 2, 2025, the Treasury Department announced suspension of enforcement of Corporate Transparency Act Against U.S. Citizens and Domestic Reporting Companies. "The Treasury Department announced that, with respect to the Corporate Transparency Act, not only will it not enforce any penalties or fines associated with the beneficial ownership information reporting rule under the existing regulatory deadlines, but it will further not enforce any penalties or fines against U.S. citizens or domestic reporting companies or their beneficial owners after the forthcoming rule changes take effect either."

If you need assistance with any required CTA reporting and/or have any questions regarding compliance with the CTA, including but not limited to whether an exemption may apply to your business or to ascertain whether relationships constitute beneficial ownership under CTA rules, we strongly encourage you to consult with qualified legal counsel experienced in this area.

We advise all clients to continue to monitor the situation as it changes often. The best resources to stay current are the Treasury website and the FinCEN website linked below.

Full press release: https://home.treasury.gov/news/press-releases/sb0038

Treasury Department: https://home.treasury.gov/

FinCen: https://fincen.gov/