Do you need to report your BOI by January 1st, or don't you?

Last week, a federal court temporarily stopped the federal government from enforcing the Beneficial Ownership Information (BOI) reporting rule under the Corporate Transparency Act (CTA). Say what?

CTA / BOI Background

Congress recently passed the CTA to curb illegal corporate finance schemes and protect national security. The CTA mandated that over 32 million U.S. companies report certain information about their company owners to the federal government's Financial Crimes Enforcement Network (FinCEN) no later than January 1, 2025.

If you have already submitted your BOI report to FinCEN, good work! Enjoy the holidays.

If you have not already submitted your BOI report to FinCEN, then you may press "pause" for now. The government will likely appeal the decision, and it will take some time for the appeal to work its way through the courts.

In the meantime, we recommend that you do three things.

Recommendations

First, if you have not already done so, figure out whether your company is covered by the BOI rule or if it is exempt from the rule.

Second, if your company is covered by the BOI rule, then gather the required ownership information and be ready to file a report on very short notice.

Third, pay attention to any news updates about CTA / BOI. If the BOI reporting rule goes back into effect, the penalties for non-compliance may be steep.

If you would like help with any of the above, please let us know--we are at your service.