Beneficial Ownership Information Reporting (BOI) Update

Effective January 1, 2024, many companies in the United States are required to report information about their beneficial owners, individuals who ultimately own or control the company to the Financial Crimes Enforcement Network (FinCEN). Twenty-three (23) types of entities, including publicly traded companies, not-for-profit entities, and certain large operating companies, were exempt from this requirement.

Who should report?

A company that is

  • a corporation, a limited liability company (LLC), or was otherwise created in the United States or
  • a foreign company that was registered to do business in any United States, state or Indian tribe

Update: Per the recent federal court order (Texas Top Cop Shop, Inc., et al. v. Garland, et al), reporting companies are not currently required to file beneficial ownership with FinCEN.

Deadline for reporting

          Company Registration Date

       Deadline

  • Prior to January 1, 2024
  • January 13, 2025
  • January 1, 2024 – December 31, 2024
  • 90 days after the receipt of the actual or public notice that the creation or registration was effective.
  • January 1, 2025, and after
  • 30 days after the receipt of the actual or public notice that the creation or registration was effective.

Update: Per the recent federal court order (Texas Top Cop Shop, Inc., et al. v. Garland, et al) reporting companies may continue to voluntarily submit beneficial ownership information reports.

Penalties

Noncompliance may be subject to civil penalties of up to $500 per day and criminal penalties  including a $10,000 fine and/or two (2) years of imprisonment.

Update: For the period that the order remains in force, reporting companies are not subject to any liability for non-reporting.

Timeless Taxes & Accounting continues to assist reporting companies file their Beneficial Ownership Information (BOI). We also offer bookkeeping, accounting and tax services for individuals and small businesses.