In 2024, we discussed the Corporate Transparency Act and the Beneficial Ownership Information (BOI) reporting rules. To recap, BOIs were originally due on January 1st, 2025, but a federal court in Texas blocked this required reporting. As we mentioned previously, we weren’t sure if that would be the final word and promised to keep you updated.
For now, according to FinCEN.gov, “Beneficial ownership information reporting requirements are now back in effect, with a new deadline of March 21, 2025, for most companies.” While we don’t know if this might change again, please save the date to submit any filings due prior to the deadline to avoid any penalties. Rest assured we will keep you posted should there be another intervention that delays or suspends this filing.
Here’s what you need to know:
Who Needs to File?
- Most corporations, LLCs, and similar entities registered in the U.S. must file a BOI report unless they qualify for an exemption.
- If you have a dissolved or inactive entity, it may still require reporting if it was active on or after January 1, 2024.
What Information Is Required?
- Companies must provide details about their beneficial owners, including:
- Full legal name
- Date of birth
- Address
- Government-issued ID number (e.g., passport or driver’s license)
- Company applicants (the individuals responsible for forming the entity) must also be disclosed for entities created after January 1, 2024.
Impact on Trusts and Estate Planning
- If a trust owns a reporting entity, trustees, grantors, and beneficiaries may need to be disclosed under the BOI requirements.
- Entities with complex ownership structures (such as those involving trusts or multiple layers of ownership) should carefully review their filing obligations.
Updating Information
- If there are changes to the ownership, control, or company details, you must update your BOI report within 30 days of the change.
Next Steps
If you own or manage a reporting entity, we strongly encourage you to:
✅ Determine whether your business must file a BOI report.
✅ Identify the beneficial owners and gather the necessary information.
✅ File the report through FinCEN’s online system before the March 21st deadline.
✅ Keep records updated to comply with future reporting obligations.
We recommend consulting with your legal or tax advisor to ensure compliance, especially if your business involves trusts or complex ownership structures.
If you have any questions about how these rules apply to your financial plan, feel free to reach out. CLICK HERE to make an appointment.
As always, we will keep you updated on any changes to these requirements!
