As of the first of calendar 2024, for all entities that are not exempt are required by federal law to make a FinCEN filing by December 31, 2024 with the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN). To comply, a FinCEN Beneficial Ownership Information Report must be filed via https://www.fincen.gov/.
A reporting company that is created or registered before January 1, 2024 has until January 1, 2025 to file its initial BOI Report.
A reporting company that is created or registered on or after the January 1, 2024, but before January 1, 2025, must file its initial BOI report within 90 days after receiving actual or public notice that the company’s creation or registration is effective.
A reporting company that is created or registered on or after January 1, 2025, must file its initial BOI report within 30 days after receiving actual or public notice that the company’s creation or registration is effective.
A reporting company has 30 days to:
Report any changes to information in its BOI report regarding itself or its beneficial owners (e.g., the reporting company changes its name or address or becomes exempt or a beneficial owner transfers their interest or there is a change to their address or unique identifying number).
Correct any inaccuracies in its BOI Report, if it becomes aware or has reason to know of the inaccuracy and such correction must be filed within 30 days after it becomes aware of the inaccuracy.
Hogue Hill does not provide the service of preparation of FinCEN filings. There are some exemptions, but we are not able to advise regarding these exemptions in light of the retirement of all attorneys associated with the firm.
Some Certified Public Accountants (CPAs) and some tax attorneys do prepare and file them for clients. This is intended to be something that the individual taxpayer can file on their own, but many find it difficult without professional assistance. There is an information site linked from the previous link, at
https://www.fincen.gov/boi . We recommend getting assistance with this from your CPA if you are not confident about handling it yourself, or it may be possible to use a corporate servicing company.