Beneficial Ownership Information (BOI) - reporting

The Corporate Transparency Act (CTA) is upon us. It took effect on January 1, 2024, and imposes a new filing requirement for most corporations, limited liability companies (LLCs), and other business entities.  The companies subject to these requirements are called reporting companies. There are two types of reporting companies:

  • Domestic reporting companies are corporations, limited liability companies, and any other entities created by the filing of a document with a secretary of state or any similar office in the United States.
  • Foreign reporting companies are entities (including corporations and limited liability companies) formed under the law of a foreign country that have registered to do business in the United States by the filing of a document with a secretary of state or any similar office.

Companies must report the following information:

  • Legal Name.
  • Any trade name or any “doing business as” (d/b/a).
  • Complete U.S. address. (PO Boxes not accepted)
  • State,Tribal, or foreign jurisdictions of formation.
  • For a foreign reporting company: State or Tribal jurisdiction of registration.
  • Taxpayer Identification Number (TIN) or foreign tax ID.

And their Beneficial Owners must provide the following information:

  • Name.
  • Date of Birth.
  • Address. (PO Boxes not accepted)
  • Driver’s license, U.S. passport, or an identification document issued by a State, local government, or Indian tribe, or a foreign passport (if none of the other document exist) An image of the document must also be provided.

People who form new reporting companies after January 1, 2024 must file a beneficial ownership information (BOI) report with the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) within 90 days of forming the company.

The owners of reporting companies created before 2024 must also file a BOI report, but they have until January 1, 2025 (but think December 31, 2024).

Some businesses are exempt from filing—for example, large operating companies with over 20 employees and $5 million in income. There are other, more narrow exemptions as well.

You must file the report electronically through the FinCEN secure BOSS (Beneficial Ownership Secure System) filing system. There is no filing fee. More information about the report filing system can be found on FinCEN website at www.fincen.gov/boi.

FAQ’s