Hey Reader,

I took a long summer break from writing my weekly email, but now I feel recharged and ready to get back to it. That's a good thing because I have an important update to share with you!

BOI Report Fling Deadline of 12/31/2024 is approaching!

Last year, I mentioned that the Corporate Transparency Act would require most companies to file a Beneficial Ownership Information (BOI) report with the Financial Crimes Enforcement Network (FinCEN) in 2024. This filing reports information to FinCEN about the individuals who ultimately own or control the company.

What You Should Do Now

1. Determine whether your company has to file a BOI report

There are several exemptions to filing a BOI report. The most common exemptions we are seeing are:

• Large Operating Companies—A company with over 20 full-time employees, more than $5 million in sales last year, and a physical location in the US is exempt from BOI reporting.
• Inactive Companies—A company that meets all of the following requirements is exempt: a company established before January 2, 2020, is not currently active in any business, is owned entirely by owners in the US, has had no ownership changes in the last 12 months, has not sent or received $1000 in any of its financial accounts in the last 12 months, and it does not own any assets.
• Tax Exempt Entities—A company that is tax-exempt under Section 501(a) of the Internal Revenue Code does not have to file a BOI report.

You can use this tool to determine whether your entity is exempt from BOI reporting: https://www.fincenfetch.com/boi-report-exemptions/.

2. Be aware of the deadlines

If your company is not exempt and has to file a BOI report, here are the deadlines for doing so:

• For companies created before January 1, 2024, you have until December 31, 2024 to file your initial BOI report.
• For companies created on or after January 1, 2024, you have 90 days to file the BOI report this year but will be required to file within 30 days in 2025 and the following years.

3. Decide how you are going to comply with the BOI reporting

You have options when it comes to fulfilling your BOI report obligation:

• DIY: File the BOI report directly with FinCEN. Watch this video by my colleague Andrew Legrand for guidance on filing your report with FinCEN: https://speralaw.com/u/fileBOIreport .
• Assisted Filing: Use our specialized service to help you with BOI reporting: BOI Report Filing Made Easy.

4. Understand your ongoing CTA compliance obligations

Although you do not have to file a BOI report every year, you do have to file an updated report when any information you reported on the BOI report changes. This could be a change in ownership of the company, a change in company management, a change in your address, or even getting a new license or passport because your old one expired! (FWIW, our firm's solution will keep track and remind you that you need to file an updated BOI report when your ID expires.)

I know this email contains a lot of information about the BOI report. As always, if you have any questions, don't hesitate to reach out!

-Addie

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