Filing Your Beneficial Ownership Information

UPDATE 3/22/2025 – BOI Is no longer required for US Citizens.
FinCEN Removes Beneficial Ownership Reporting Requirements for U.S. Companies and U.S. Persons, Sets New Deadlines for Foreign Companies

WASHINGTON––Consistent with the U.S. Department of the Treasury’s March 2, 2025 announcement, the Financial Crimes Enforcement Network (FinCEN) is issuing an interim final rule that removes the requirement for U.S. companies and U.S. persons to report beneficial ownership information (BOI) to FinCEN under the Corporate Transparency Act.

In that interim final rule, FinCEN revises the definition of “reporting company” in its implementing regulations to mean only those entities that are formed under the law of a foreign country and that have registered to do business in any U.S. State or Tribal jurisdiction by the filing of a document with a secretary of state or similar office (formerly known as “foreign reporting companies”). FinCEN also exempts entities previously known as “domestic reporting companies” from BOI reporting requirements.

Thus, through this interim final rule, all entities created in the United States — including those previously known as “domestic reporting companies” — and their beneficial owners will be exempt from the requirement to report BOI to FinCEN. Foreign entities that meet the new definition of a “reporting company” and do not qualify for an exemption from the reporting requirements must report their BOI to FinCEN under new deadlines, detailed below. These foreign entities, however, will not be required to report any U.S. persons as beneficial owners, and U.S. persons will not be required to report BOI with respect to any such entity for which they are a beneficial owner. For more information, see https://fincen.gov/news/news-releases/fincen-removes-beneficial-ownership-reporting-requirements-us-companies-and-us.

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Beginning Jan 1, 2024, business owners are required to file Beneficial Ownership Information. If you have a business that you created, and it does not meet the exemptions (which our businesses do not), then you need to file.

This 10-minute video breaks it. I talk about:

• What is it?
• Who must report?
• What you need to report
• Who is a beneficial owner?
• Privacy
• How and where to file

It really is easy to do. I’ll post the references below the video.

UPDATE Jan 20, 2024

Due to the legal challenges to this ruling, it’s requirements are up in the air. This is from the BOI webiste:

In light of a recent federal court order, reporting companies are not currently required to file beneficial ownership information with FinCEN and are not subject to liability if they fail to do so while the order remains in force. However, reporting companies may continue to voluntarily submit beneficial ownership information reports.

If you have not yet submitted your filing, I recommend you keep up to date regularly with the BOI website. The last thing you’ll want is to miss a filing deadline, as the fines are costly. (See the alerts on this page: https://www.fincen.gov/boi)

References/Resources

• Financial Crimes Enforcement Network
• US Beneficial Ownership Information Now Accepting Report
• What every small business needs to know about the Corporate Transparency Act and Beneficial Ownership Information Reporting.