Update on Beneficial Ownership Information Reporting
February 7, 2024
As the Corporate Transparency Act (“CTA”) became effective 1/1/24 for newly formed entities, and many existing entities being required to file by 12/31/24, Nisivoccia LLP wants to provide some updated information.
The CTA requires certain entities to complete the Beneficial Ownership Information (“BOI”) report disclosing ownership, control and other information. The completion of this requirement could be considered the practice of law. Therefore, at this time Nisivoccia LLP is not assisting in the compliance reporting under the CTA.
The compliance of CTA is being administered by the Financial Crimes Enforcement Network (“FinCEN”). FinCEN has a Small Entity Compliance Guide and frequently asked questions to help guide businesses through the exemptions to file as well as reporting requirements. These are available at https://www.fincen.gov/boi/small-business-resources.
If required to file, the BOI reports must be filed electronically. FinCEN’s e-filing portal, available at https://boiefiling.fincen.gov/, provides two methods to submit a report: (1) by filling out a web-based version of the form and submitting it online, or (2) by uploading a completed PDF version of the BOI report. Some third-party service providers may also offer the ability to file the BOI report through their software. The person who submits the BOI report will need to provide their name and email address to FinCEN. There is no fee for filing the report.
While you may self-file your BOI report, if you need assistance determining if exempt, completing the filing, and determining who must be listed as substantial beneficial owners, etc., we encourage you to consider consulting with legal counsel.
3rd party service providers are assisting with navigating and filing of the BOI reports.
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