BENEFICIAL OWNERSHIP INFO

As of Jan. 1, 2024, certain types of corporations, limited liability companies and other similar entities created in or registered to do business in the United States must report information to FinCEN about their beneficial owners—the persons who ultimately own or control the company.

BOI reporting is not an IRS program; all inquiries must be directed to FinCEN.

Ownership Info – File OnlineBOI e-filing System

File from BOI website, click Beneficial Ownership Information (BOI) Reporting – Get Started

You will need:
1. State Issued Photo ID. Must attach to application
2.. Must use Adobe Reader to complete form

Note
1. Sole Proprietors don’t need to file
2. LLC must file, cause filed with Secretary of State
Financial Crimes Enforcement Network (FinCen)FinCen – website

FinCen website takes you to BOI e-filing system to file report.
News ReleaseView Alert Notices

12/26/24 You Do NOT have to file BOI. A panel of the U.S. Court of Appeals for the Fifth Circuit reinstated a nationwide injunction that suspend enforcement of BOI reporting requirement.

12/23/2024 You MUST file BOI by 1/13/2025. U.S. Court of Appeals for Fifth Circuit granted a stay of the district court’s preliminary injunction. Therefore BOI back in effect. Deadline to file extended to 1/13/2025.

12/3/2024 You do NOT have to file BOI. Texas District Court Injunction – issued Ordered; hold on BOI filing nationwide.

1/1/2024 Release Notice
FAQFAQ

Company Closed Before BOI went into effect 1/1/2024: C. 13. Is a company required to report its beneficial ownership information to FinCEN if the company ceased to exist before reporting requirements went into effect on January 1, 2024?

Company Opened and Closed in 2024: C.14

Beneficial Owner: D.1

Substantial Control: D. 2

Nonprofits – 501(c)(3) organizations are generally exempt from BOI reporting requirements.  However, that assumes a nonprofit already has a 501(c)(3) determination letter from the IRS.  If they do not, they are liable to report to FinCEN

Partnerships (1065). exempt from filing BOI (do not file); because partnership is not registered / form with state.
Submit BOI
Info Needed
Reporting Company
– Company doing business in the U.S.

– Excludes:  (FinCen C.2) Sole Proprietor, General Partnerships, etc.

– Info Needed
1. Name as Filed with State
2. DBA, if any
3. EIN / SSN
4. Current U. S. Address
OR, can use FinCEN ID for the company. I.E., company applied for finCEN ID

Company Applicant
– This is the person that filed the documents with the State to create the company

– (FinCen E.5) Can be a Maximum of two people:
1. the person who directly files the document with a secretary of state or
similar office, and
2. if more than one person is involved in the filing of the document, the person who is primarily responsible for directing or controlling the filing.

-Info Needed – for Each Individual (remember maximum 2)
1. Legal Name
2.  Date of Birth
3.  Address (can be business or residential; inside or outside U.S.)
4.  Copy of ID (driver’s license or passport)

Each Beneficial Owner
– The individual that directly or indirectly controls the company, or owns at least 25% interest in company (FinCen D.1)

– There is NO maximum number.  All owners must be reported.

– Info Needed – for Each Individual (remember NO maximum)
1.  Legal Name
2.  Date of Birth
3.  Residential Address (can be inside or outside U.S.)
4.  Copy of ID (driver’s license or passport) — check expire date. or FinCEN ID

Submit
1. Enter client’s email address and anme
2. Download / Print confirmation transcript
Office ProcessNotify Clients BOI Needs to be Filed (Filing Requirements)
1. Send Notice via Email

For Clients Who Want Us to File their BOI
1. Update BOI List (Admin Folder /Office Forms /BOI / BOI List)
a. Highlight Client in BOI List
b. In Notes column, enter “Request we do BOIR”

2. Add Client to Covid Spreadsheet, Tab =Filings. Set Filing type to BOI

3. Gather info / Email Client for Missing Info (create Project Activity folder)
a. Business Info (name, ein/ssn, address)
b. Company Applicant (name, date of birth, address, copy of ID)
c. Owner(s) Info (name, date of birth, residential address, copy of ID)
d. How many beneficial owners

4. Email Susan to send invoice. Include:
a. Total Fee, Number of Beneficial Owners
b. Company Name, Contact Name

5. Susan / Justin Update Payment Status in covid spreadsheet

6. File BOI (once payment received); and Print BOI Transcript / Confirmation
Do not Create FinCen ID, because email is unique to filing (i.e., need different email for each FinCen ID). Instead, just complete the application

7. Save Docs to Client’s Msever and Sharefile. Folder: SOI – BOI Filings
FinCEN IDInfo – Instructions | Application
A FinCEN ID is a 12-digit number.

Individuals – FinCEN ID starts with the number 3

Entities (Business) – FinCEN ID starts with the number 2
How Get FinCEN ID1. Go to https://www.fincen.gov/boi

2. Click “Create a FinCEN ID (optional)”

3. Click Sign in or Create an Account

4. Click Sign in

5. If you do not have an US Department of Treasury account, Click create an account, enter all relevant information, and click submit. If you do have an account, click Sign In.

6. Go to the email address that you just provided to FinCEN to confirm your email address. They will send an email.

7. Create a 12-character password.

8. Choose a multifactor option to secure your account. The recommended option is text/voice message as that will just send a code to your phone via text or phone call.

a. Input your phone number after confirming this option for your multifactor, click either text or phone call for how to get the code, and then click send code to get the code sent to the option you have selected.

9. IF you are tech savvy, and have an authentication app, then that is the best choice.
a. Open your Authenticator app and scan the QR code. Input the code on the app into step 4 on that same page. You will have to give it a nickname to proceed.

10. Skip adding another authentication method. You can always add more later. We just want to get the FinCEN number for the BOI report.

11. Click agree and continue

12. You will be redirected to the FinCEN home page.

13. Click Sign in on the home page

14. You will be sent to the FinCEN identifier application. Fill in all necessary information and click submit.
a. You will need to provide a form of ID (passport, DL, state ID, etc.) at this part.

b. If you do not have a copy/picture of this on your computer, you can take a picture of your form of ID and email it to yourself. You will then download that form of ID you just emailed to your computer. Click and drag the image from your downloads folder or you can click “choose from folder”, go to your downloads folder, and double click on the ID you just downloaded from your email.

15. Once you submit that info, you will be sent to a page with your FinCEN ID. Please click download and send it to the manager who is filing the BOI report. IF you are the manager, then use that ID number to file your BOI report.

16. If you think you need to update or change anything on the account, you can do that at any
time