Who is Required to Comply with Beneficial Ownership Information?
Who is a Beneficial Owner?
Beneficial owners are typically classified as individuals (or sub-entities) that meet either of the following criteria:
- Directly or indirectly own at least a 25% interest in a business entity
- Exercise substantial control over a reporting company
What Information is Required to be Reported?
Each business entity must report the following information:
- Full legal name (and any DBA) of the business
- Address
- State of formation
- EIN/ITIN
Additionally, the business entity must report the following information on each of its beneficial owners (individual or entity):
- Name
- Birthdate
- Address
- Copy/image of a unique identifying number and issuing jurisdiction from an acceptable identification document (generally required to be a drivers license or a passport)
What are the Beneficial Ownership Information (BOI) Filing Deadlines?
The requirement to file Beneficial Ownership Information (BOI) reports typically applies to a broad range of legal entities. These include corporations, limited liability companies (LLCs), and similar structures registered or operating within a jurisdiction. The specific criteria can vary depending on the country’s regulations, but generally, the entities that must file are those that:
- Existing entities (in existence before 1/1/2024) will be required to file by January 1, 2025
- Any new entities created or registered on or after 1/1/2024 will have 90 days to file after their registration/establishment date
- If there is any change to the information reported (including a renewal or expiration of the identification document), then you have 30 days to file the updated information to FinCEN
- If there are any corrections that need to be made to the report, they must be made within 30 days from when the error was discovered or from when you had reason to know of the error
What Happens if I Don't File a BOI Disclosure Report?
Failure to comply can result in a penalty of $500 per day, up to $10,000 total, and up to 2 years of jail time.
How Can CMP Help?
CMP will be actively engaged, helping clients and other business owners with this new filing requirement. Please reach out to your CPA to coordinate our efforts in assisting you. If you have any questions regarding the CTA/BOI, please feel free to reach out to any of our staff and they can assist you as well.
The deadline to submit information to CMP for existing entity filings is November 30, 2024.
How Much Does Beneficial Ownership Information Filing Cost?
CMP’s base fee for BOI reporting is $300.
Keep in mind that this service is completely separate from any tax return filing, and CMP will only be providing this service if requested. If CMP provides this service then it will be under a separate engagement letter specifically for BOI reporting purposes, and will be limited to initial filings. Any subsequent event triggering an updated filing, will require a new engagement.
Click the button below and fill out a form, and we will contact you in May to ensure your company is compliant.
