Hey all! Hopefully your holiday season is filled with peace, love and joy. While there is MUCH yet to evolve, so please consider this information as a preliminary heads up, not anything binding, during 2024 "FinCen" (you can look up the acronym - https://www.fincen.gov/boi-faqs) is requiring annual filing of 'beneficial ownership interests" by December 31, 2024. The site shows that filing can begin January, 2024, electronically but basically shows the system is not yet in place. Short version, put this on the radar - hopefully it will end up being not that a big of a deal but right now, from my angle, it seems riddled with potential pain points.
But hey, I'm here to help and we'll figure out a way to keep our friends in DC happy as the process evolves. Again, for today I just want to make sure people are aware this is out there. Oh - and if a new business starts in 2024 - there is a 90 day period in which to file the "beneficial ownership information reporting.' As an added bonus, indications are if any information changes regarding beneficial owners (asking - like driver's license renewals?) those changes must be reported within 30 days of the change.
Small business clients, I'll have more information about this in the upcoming engagement letters I'll be sending out. Following is from the Q&A on the site. Questions? Me, too! But we'll figure it out together.
When do I need to report my company’s beneficial ownership information to FinCEN?
Answer: A reporting company created or registered to do business before January 1, 2024, will have until January 1, 2025 to file its initial beneficial ownership information report.
A reporting company created or registered on or after January 1, 2024, and before January 1, 2025, will have 90 calendar days after receiving notice of the company’s creation or registration to file its initial BOI report. This 90-calendar day deadline runs from the time the company receives actual notice that its creation or registration is effective, or after a secretary of state or similar office first provides public notice of its creation or registration, whichever is earlier.
Reporting companies created or registered on or after January 1, 2025, will have 30 calendar days from actual or public notice that the company’s creation or registration is effective to file their initial BOI reports with FinCEN.
[Updated December 1, 2023]
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