Beneficial Ownership Information Reporting

The Federal Government now requires all businesses to report all individuals and legal entities that have control over entities conducting business in the US under the Corporate Transparency Act.  For all businesses established prior to January 1, 2024, they have until December 31, 2024 to complete the Beneficial Ownership Information Reporting (BOI) form in compliance with the new law.  Entities established on or after January 1, 2024, must report within 30 days of establishment to avoid fines.  There are exemptions from the BOI reporting requirements:

1. Tax-Exempt (must meet one criteria)
   1. The organization is a 501(c) and exempt from tax under the section 501(a)
   2. Entity is a political organization in section 527(e)(1) and exempt from tax under the section 501(a)
   3. Entity is a trust in paragraph (1) or (2) of section 4947(a)
2. Inactive entity (must meet all 6 criteria)
   1. Entity was created prior to 1/1/20
   2. Entity not engaged in active business
   3. No foreign person, whether directly or indirectly, wholly or partially is an owner of entity
   4. Entity has not experienced any change in ownership in the preceding 12 months
   5. Entity has not sent or received any funds in an amount greater than $1,000, either directly or through any financial account in which the entity or any affiliate of the entity had an interest, in the preceding 12 months
   6. Entity does not otherwise hold any kind or type of assets, whether in the US or abroad, including any ownership interest in any corporation, limited liability company, or other similar entity
3. Securities reporting issuer
4. Governmental authority
5. Bank
6. Credit union
7. Depository institution holding company
8. Money services business
9. Broker or dealer in securities
10. Securities exchange or clearing agency
11. Other Exchange Act registered entity
12. Investment company or investment adviser
13. Venture capital fund adviser
14. Insurance company
15. State-licensed insurance producer
16. Commodity Exchange Act registered entity
17. Accounting firm
18. Public utility
19. Financial market utility
20. Pooled investment vehicle
21. Entity assisting a tax-exempt entity
22. Large operating company
23. Subsidiary of certain exempt entities

The information reported on the BOI form is:

1. Business legal name
2. EIN or SSN
3. Country of formation
4. US mailing address
5. Company Applicant (individual completing the form)
6. Beneficial Owner Information (any individual who directly or indirectly exercises substantial control over the company or who owns at least 25% of the ownership interests of the company)

Please contact Jessi at [email protected] if you need any assistance with this reporting requirement.