Submission of Beneficial Ownership Information (“BOI”) to FinCEN

The Corporate Transparency Act requires many small businesses to report information about their beneficial owners to the Financial Crimes Enforcement Network (FinCEN). Both domestic and foreign reporting entities are required to file. A company is considered a reporting entity if a document was filed with the secretary of state or similar office. Corporations, partnerships and LLCs are subject to these requirements.

There is an exemption from BOI reporting for large operating companies. To qualify as a large operating company, all three must apply:

  • More than 20 full-time employees are employed in the US.
  • Has an operating presence at a physical office within the US.
  • Filed a federal income tax or information return in the US for the previous year showing more than $5,000,000 in gross receipts or sales.

There are additional BOI reporting exemptions as outlined in link below:

BOI – General Reporting Guide

A reporting company created or registered to do business before January 1, 2024, will have until January 1, 2025, to file its initial beneficial ownership information report.

A reporting company created or registered on or after January 1, 2024, and before January 1, 2025, will have 90 calendar days after receiving notice of the company’s creation or registration to file its initial BOI report.

If you would like to engage Lutz Selig & Zeronda, CPAs, LLP to assist with your initial BOI submission to FinCEN, please reach out to your engagement partner.