Information about the FinCEN Beneficial Ownership (BOI) report

Beginning on January 1, 2024, many companies in the United States will have to report information about their beneficial owners, that is, the individuals who ultimately own or control the company.  FinCEN will begin accepting the new beneficial ownership information reports on January 1, 2024.

Who is required to file the new report?

Companies required to report are called reporting companies. There are two types of reporting companies:

• Domestic reporting companies are corporations, limited liability companies, and any other entities created by the filing of a document with a secretary of state or any similar office in the United States.
• Foreign reporting companies are entities (including corporations and limited liability companies) formed under the law of a foreign country that have registered to do business in the United States by the filing of a document with a secretary of state or any similar office.

To determine if the company meets these requirements, see the FAQ here.

How to file the new report:

If the company is required to report their company’s beneficial ownership information to FinCEN, you will do so electronically through a secure filing system available via FinCEN’s website and not with the tax return. To access the BOI E-Filing system see here.

When to file:

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. This 30-day deadline runs from the time the company receives actual notice that its creation or registration is effective, or after a secretary of state or similar office first provides public notice of its creation or registration, whichever is earlier.

Our Approach

Given the legal and professional risks associated with BOI reporting, many in the industry are taking a cautious approach. We're doing the same.

• Self-service Encouraged: 

We recommend that your clients handle BOI filings themselves or through a legal service. Most firms will have clients handle their own filings, and those who don't usually limit this service to a select few clients.

• Legal and Compliance Considerations: 

We've noted significant concerns from insurance providers and legal advisors about the risks of CPAs filing these reports, potentially leading to professional liability issues.

Helpful resources:

• For frequently asked questions, see Beneficial Ownership Information Reporting.
• The Small Entity Compliance Guide can be found here.
• To check on the status of the online filing system and forms availability see here.
• You can file directly via FinCEN's portal at fincen.gov.
• Reference the QuickBooks Blog to read about all the information you can relay to your clients: The Beneficial Ownership Information (BOI) report: What small businesses need to know + BOI form.
• The Beneficial Ownership Information report can now be filed through QuickBooks Online. Log in or sign up* to QuickBooks to complete and file your BOI report here.