First we need to alert you of the new reporting requirements. And NOTE we are NOT attorneys. You need to do this and it is very easy and NO you do not need to pay anyone to do this for you.
We want to bring to your attention a VERY VERY important update regarding the reporting requirements established by the Financial Crimes Enforcement Network (FinCEN). The Corporate Transparency Act (CTA) mandates that FinCEN create standardized procedures for the reporting, maintenance, and disclosure of beneficial ownership information (BOI).
Who Needs to Report?
The new requirements apply to both domestic and foreign reporting companies. A domestic reporting company includes corporations, limited liability companies (LLCs), and any other entities formed by filing documents with a state secretary or similar office. A foreign reporting company is defined as any corporation, LLC, or other entity created under the laws of another country that is registered to do business in any U.S. state or Tribal jurisdiction.
When Does Reporting Begin?
FinCEN started accepting reports of beneficial ownership information on January 1, 2024. If your company was formed or registered before this date, you have until January 1, 2025, to submit your initial report. Companies established or registered in 2024 will have 90 days to file their initial report, while those formed after 2024 will have 30 days.
Identifying Beneficial Owners
A beneficial owner is defined as an individual who directly or indirectly exerts substantial control over a reporting company or owns at least 25 percent of its ownership interests. This includes individuals with significant management responsibilities, such as executive officers or senior managers. In some instances, a company applicant—who files the registration documents—must also be reported. This can include an employee or an attorney who files on behalf of the company.
It’s essential to provide the residential street address for each beneficial owner and the applicant, depending on the situation. Proof of identification, such as a passport or driver’s license, will be required for each beneficial owner, and documents should be uploaded via the FinCEN website.
How to Report
The reporting process requires detailed information about your company and each beneficial owner or applicant, including their legal names, trade names, addresses, jurisdiction of formation, Taxpayer Identification Number, and a unique identifying number from an acceptable ID.
We offer two options for reporting: a form-filled PDF that can be saved for future use and an online version available on the FinCEN website. Note that the online version must be completed in full for each future report.
Filing Instructions
The government has released a 21-page filing instruction document, which can be accessed at
FinCEN Filing Instructions.
How to File
You can complete your filing on the FinCEN website:
File Your BOI Report.