November 18, 2024
As the December 31, 2024, deadline looms to report Beneficial Ownership Information (BOI) as part of The Corporate Transparency Act, we wanted to make sure members are equipped with the information they need to file their information and remain compliant. The following are questions we’ve heard from customers. In addition, we presented a webinar in June that dove deeper into the BOI reporting requirements. To review the full recording from this webinar, click here.
When can you begin filing?
The portal is open to start filing. Visit FinCEN.gov to file.
When must this information be filed by?
Existing entities must file their BOI reporting by December 31, 2024. New entities must file within 90 days of creation in 2024, and within 30 days from January 1, 2025, onwards.
What information will need to be reported?
The following information is required to be reported for the company:
- Full legal name
- Any trade names used by the company (DBA)
- Street address of the company’s principal place of business
- The jurisdiction in which the company was formed or registered
- Taxpayer Identification Number (EIN)
The following information is required to be reported for each beneficial owner:
- Full legal name
- Date of birth
- Residential address
- Identification number from a government-issued ID
- An image of the government-issued ID
How long will it take to file?
If you're a simple business structure, husband and wife, 50-50 LLC, etc., FinCEN estimates it should about 1 hour and 30 minutes to complete filing. More complex businesses will take more time depending on the business’s complexity.
The most time-consuming part is inputting the information. The filing itself is relatively easy to complete.
Is there a fee to file?
If you file directly through FinCEN, it is free to file.
Will FinCEN tie in with login.gov?
If you request an identifier from FinCEN, then you will need to create a login.gov account there, so there is some tie-in in that regard.
Will Farm Credit East be filing these obligations for LLCs?
No, Farm Credit East will not be filing these obligations for LLCs.
If my tax preparer does not file this, who can help me?
You may want to seek advice from your attorney, particularly if you have complex structures to determine who may be in substantial control of the business.
Will there be penalties for late filings?
Yes, there will be penalties for late filing. After January 1, 2025, it's $500 per day (adjusted annually for inflation) until the required information is filed to become compliant. Non-compliance could also result in criminal penalties of up to $10,000 and/or up to two years of imprisonment for willful neglect.