Beneficial Ownership Information Resources
Updated: Jan. 3, 2025
Note: On Thursday, Dec. 26, a U.S. appeals court reinstated a nationwide injunction that had been overturned days prior. This decision means that FinCEN no longer has the authority to enforce Beneficial Ownership Information (BOI) reporting requirements at this time.
It is advised that those assisting clients with BOI filings continue gathering the required information from clients and to be prepared to file BOI reports if the injunction is lifted again.
The U.S. Department of Justice has requested the Supreme Court to block in the injunction.
The MNCPA will monitor this issue as it progresses.
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The Beneficial Ownership Information (BOI) framework, established under the Corporate Transparency Act (CTA) of 2021, requires the disclosure of BOI data to the Financial Crimes Enforcement Network (FinCEN).
This initiative empowers FinCEN to gather and distribute beneficial ownership details to law enforcement agencies, financial institutions, and authorized entities, thus enhancing transparency and reducing opportunities for individuals to conceal or profit from illicitly acquired assets.
As of Jan. 1, 2024, FinCEN started requiring BOI reports. Noncompliance includes substantial civil and criminal penalties.
This page will be continuously updated with new information as it becomes available.
Who needs to report?
Companies referred to as “reporting companies” will be required to report their beneficial ownership information to FinCEN. There are two types of reporting companies — domestic reporting companies and foreign reporting companies.
There are 23 types of entities that are exempt from the reporting requirements. Carefully review the qualifying criteria before concluding that your company is exempt.
See this flowchart and more in the
Small Entity Compliance Guide
When do you need to do something?
The reporting requirement is effective Jan. 1, 2024. FinCEN will not accept BOI reports before then.
See this timeline and more in the
Small Entity Compliance Guide.
What information do companies need to report?
- Full legal name of the reporting company or any trade or DBA names.
- Business address.
- State or Tribal jurisdiction of formation or registration.
- IRS TIN.
- Information about its beneficial owners, and for newly created companies, it’s company applicant(s), including: name, birthdate, address and unique identifying number and issuing jurisdiction from an acceptable identification document.
Are there penalties for noncompliance?
- Civil penalties are up to $500 per day that a violation continues.
- Criminal penalties include a $10,000 fine and/or up to two years of imprisonment.
Articles and resources
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Resources |
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DOJ asks Supreme Court to block injunction on BOI reporting
Journal of Accountancy
Jan. 3, 2025
Appeals court reinstates injunction that halts BOI enforcement
Journal of Accountancy
Dec. 27, 2024
BOI injuction lifted; reporting deadling is Jan. 13, 2025
Journal of Accountancy
Dec. 23, 2024
Extension to BOI reporting deadline removed from budget bill
Journal of Accountancy
Dec. 20, 2024
Corporate Transparency Act blocked nationwide by Tax Court
Bloomberg Tax
Dec. 4, 2024
AICPA to Congress Day: Delay needed in BOI reporting deadline
Journal of Accountancy
Nov. 13, 2024
BOI reporting relief to natural disaster victims
FinCEN
Oct. 30, 2024
BOI reporting lagging ahead of deadline
MNCPA
Oct. 11, 2024
BOI requirements roll along despite concerns about too little outreach
Journal of Accountancy
Aug. 6, 2024
The Corporate Transparency Act: Where are we now?
The Tax Adviser
April 19, 2024
Update FAQs provide details on phase-in timing of BOI access
Journal of Accountancy
April 8, 2024
Uncertainty surrounds CTA — for accountants and small biz
Accounting Today
April 4, 2024
Decision holding Corporate Transparency Act unconstitutional appealed
Journal of Accountancy
March 12, 2024
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Frequently Asked Questions
FinCEN
Sample BOI reporting engagement letter
AON
Small Entity Compliance Guide
FinCEN
Primer: What you need to know about BOI reporting
MNCPA
BOI reporting FAQ
FinCEN
Letter sent to Treasury, FinCEN
AICPA, cosigned by MNCPA
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