Recently, we sent out an email about the 2024 mandate to report Beneficial Ownership Information (BOI) to the Financial Crimes Enforcement Network (FinCEN) enacted as part of the Corporate Transparency Act (CTA).

Any company (LLC, Corporation, Partnership, etc.) started before 2024 is required to file this information. Even if the entity was started and never used, the business activity has yet to begin, or the entity has not yet been dissolved with the secretary of state or similar office. This mandate includes LLCs or partnerships that may hold rental properties, other assets, other business activities, or be used for legal liability protection. Entities started before 2024 have until 1/1/25 to file this information with FinCEN.

For any new entities set up in 2024, the BOI reporting is due within 90 days of the entity’s creation date with a secretary of state or similar office in the United States.

Our firm will NOT be providing these services to our clients, as this is not a tax filing requirement but an informational legal filing requirement. Our engagement letters will also mention we will not be providing these services.

You are responsible for the BOI reporting requirements and collecting the relevant ownership information requested. We suggest reaching out to your trusted legal advisor to discuss the applicability of this reporting requirement in your specific situation.

We caution that some unscrupulous vendors may be attempting to gather this information to file on your behalf. If you receive these solicitations, we highly recommend vetting these companies to ensure your information will be safe and secure.

At the time of our previous email, the FinCEN website was under construction. The website is now active at https://www.fincen.gov/boi. There are also pages dedicated to FAQs and reference materials.