Did You Business File the Beneficial Ownership Report Yet?

Beginning on January 1, 2024, many corporations, limited liability companies, limited partnerships and other entities created or registered to do business in the United States with a Secretary of State must report information about their beneficial owners—the persons who ultimately own or control the company—to the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN).

This law applies to domestic companies and foreign companies to help law enforcement fight financial crimes.

The effective date depends on whether your organization was formed before or after January 1, 2024.

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, will have 30 days to file its initial beneficial ownership information report. There is a special 90 day rule for companies formed in 2024 only)

Major exceptions:

1.     regulated companies such as investment advisers

2.     Tax-exempt entities

3.     large operating companies. A large operating company is any entity with all 3 of these:

(a) more than 20 full-time U.S. employees, AND

(b) an operating presence at a physical office within the U.S., AND

(c) more than $5,000,000 of U.S.-sourced gross receipts reported on its prior year federal income tax return. (If you didn’t file a tax return you don’t qualify.)

You file at https://boiefiling.fincen.gov/fileboir

I DO NOT PREPARE THESE AS THE OWNERS NEED TO SUBMIT IDs (SUCH AS DRIVERS LICENSE OR PASSPORT) WITH THIS REPORT.