Introduction to the Corporate Transparency Act (CTA), Beneficial Owner Information (BOI) and FinCEN Reporting
- What government offices are considered a "similar office" to a secretary of state, in regard to creating or registering a company in the U.S.?
- Is a company required to file an updated BOI report upon dissolution? Are there post-dissolution BOI reporting requirements?
- When does a company cease to exist?
- If a reporting company created or registered in 2024, or later, winds up its affairs and ceases to exist before its initial BOI report is due, is it still required to submit that initial report?
- Do BOI reporting requirements apply to companies created or registered before the CTA was enacted (January 1, 2021)?
- Is a company required to report its beneficial ownership information if it ceased to exist before January 1, 2024? Does a company that ceased to exist have to submit an initial BOI report?
Filing Corporate Transparency Act Reports
- Must third-party service providers keep records proving they are authorized to file for a reporting company?
- Who can file a BOI report on behalf of a reporting company, and what information will be collected on filers?
- If a reporting company created or registered in 2024, or later, winds up its affairs before its initial BOI report is due to FinCEN, is it still required to submit the report?
- Who can file a BOI report for a reporting company created or registered in 2024 or later that ceases to exist before its initial report is due?
- If an initial report was filed directly with FinCEN (or another 3rd party platform) - are we able to file a correction or updated filing?
- What payment methods are accepted by the BOI platform? How do I pay for my BOI report? Does the platform provide refunds?
Beneficial Owner Information (BOI)
- Does the name on an individual’s acceptable identification document need to match the individual’s current full legal name
- Do reporting companies need to report the addresses of individuals in an Address Confidentiality Program (ACP)?
- If one spouse owns part of a reporting company, would the other spouse be a beneficial owner in a community property state?
- What if a reporting company does not have any individuals who own or control at least 25 percent? What if all owners are less than 25%?
- What happens when a company is owned by a trust? Who are the Beneficial Owners when individuals own or control the company through a trust?
- Are entities formed under Tribal law required to report beneficial ownership information?
Reporting Company Information
- What type of tax identification number should be reported by a reporting company that is disregarded for U.S. tax purposes? What about Disregarded Entities?
- Is a sole proprietorship a reporting company? Are sole proprietors required to file a BOI report?
- If a reporting company created or registered in 2024, or later, winds up its affairs and ceases to exist before its initial BOI report is due, is it still required to submit that initial report?
- What details must be included about a reporting company? Are we required to report a DBA or Trade Name?
- What information does a reporting company have to provide on a BOI Report? What do we report for our company?
- What additional information does a Reporting Company need to disclose?
Company Applicant
- Who is the Company Applicant of a reporting company? When does a Company Applicant need to be disclosed?
- Who is a company applicant?
- Does every reporting company have to identify a company applicant?
- What details must a reporting company provide for each Company Applicant?
- Can a Company Applicant be Removed from a BOI Report?
- Who is the Company Applicant when using an automated incorporation service?
Acceptable Forms of Identification for Beneficial Owners
- What file formats are acceptable for identification / ID upload? When uploading ID - Identification - what file type is accepted? Are PDF files accepted for ID uploads to the BOI platform?
- Which identification documents fulfill the reporting requirement? What documents must I submit with my BOI filing?
- Will FinCEN accept an identification document without a photograph for religious reasons?
Understanding BOI Reporting Exemptions
- If my legal entity only passively holds property - and is otherwise inactive - do I need to file BOI?
- Is my business too small to be required to file a BOI report?
- Does a reporting company qualify for the large operating company exemption if it is run from a personal residence?
- Does a company qualify for the large operating company exemption if it has not yet filed its Federal income tax or information return for the previous year?
- Compliance Quiz - How do we determine if we are exempt from filing a BOI report?
- Are some companies exempt from filing a BOI report? Who is exempt from filing a BOI report?
Updating Corporate Transparency Act Reports
- Does a reporting company need to file a new beneficial ownership report each time it registers to do business in a new state?
- Does converting from one entity type to another (e.g., corporation to LLC) require filing a new beneficial ownership report with FinCEN?
- What if information on a previously submitted BOI report has changed or a mistake was made?
- Do we need to correct previously submitted inaccurate information to FinCEN? Are we required to correct a prior BOI filing?
- What is the procedure for rectifying inaccuracies in a report?
- What events require me to file an updated beneficial ownership information report?
FinCEN Identifiers
- Does a reporting company need to update its BOI report if a beneficial owner or applicant changes their FinCEN identifier information?
- How can I use a FinCEN identifier?
- What is a "FinCEN identifier"?
- How can one obtain a FinCEN identifier?
- How is a FinCEN identifier utilized?
- Are FinCEN identifiers obligatory?
Compliance & Enforcement
- Is beneficial ownership information reported to FinCEN accessible under the Freedom of Information Act (FOIA)?
- Must a foreign company report its BOI to FinCEN if it stopped doing business in the US before the January 1, 2024 reporting requirements?
- What should a reporting company do if a beneficial owner or company applicant withholds information?
- Is a reporting company responsible for ensuring the accuracy of the information that it reports to FinCEN, even if the reporting company obtains that information from another party?
- Who can be held liable for violating BOI reporting requirements? Can an individual be held liable?
- What happens if a reporting company does not report beneficial ownership information to FinCEN or fails to update or correct the information within the required timeframe?
State Beneficial Ownership Information Laws
Partner Resources
- What are Promo Codes and how do they work? Can we apply different fees for different clients? How do we set up discounts?
- What is Preparer Review? If Preparer Review is turned on - what happens?
- What are "Report Credits" and how do they work?
- What are the differences between the three user types on the SnapBOI platform: Company Contact, Preparer, and Principal Preparer?
- Who receives the BOI filing confirmation? Does the beneficial owner receive the FinCEN filing confirmation? What does my client receive after completing a BOI report?
- What is an Engagement Letter?