Bob,

The 'reservations' to the BOI regime come from the lack of foresight or effort that went into its design.  I realize, for Congress, any action is like watching sausage being made.  However, the drafting of good laws - those that stick around for more than one cycle and do more good than harm - require a significant amount of planning.  Clearly, that was not the case here (as noted by all of the comments in this blog).  Upon implementation, we will have expansive knowledge as to the owners of every local pizza shop and liquor store, but no greater knowledge as to who controls our defense contractors, technology infrastructure or financial institutions; or for that matter, who just walked across our 'border.'  It seems like a massive amount of effort for very little gain.  I won't even mention the privacy aspects of a database that will inevitably be hacked, or worse, used for marketing, politics or other deviant purposes.  I know, we're only talking about the local pizza shop, but that party is probably the lowest on the food chain when it comes to risk management (pun intended).  Serving our clients requires consideration of all these aspects, now and into the future, not just a determination of whether we can draft an engagement letter adequate to perform an end run around the unauthorized practice of law.  Quite frankly, I don't think any of my clients will be better off as a result of this undertaking.  If it is a KYC/AML issue, then the parties at the front end of that infrastructure should be responsible for addressing those issues not the guy trying to prepare a simple tax return for a small business (as this isn't a large business issue).  To that end, we've been down this road before.  We spent a great deal of effort trying to cram healthcare into a tax return and that didn't work out so well either.  Just my optimistic view.