Should BOI Deadline Be Delayed?

Under the Corporate Transparency Act (CTA), FinCEN has recently created new beneficial ownership reporting obligations that apply to all domestic reporting companies (including corporations, LLCs, limited partnerships and any entity formed by filing a document with a secretary of state in the U.S). The company's beneficial owners must be identified and reported to FinCEN (the reporting deadline is January 1, 2025 for business entities formed before January 1, 2024; companies formed during 2024 have 90 days to report and companies formed in 2025 and beyond have 30 days). The company must report the entity's (1) legal name, (2) any trade names or dba names, (3) principal place of business, (4) state of formation and (5) unique taxpayer ID number. For each beneficial owner, the company must disclose (1) full legal name, (2) date of birth, (3) address, (4) identifying number from the individual's ID (driver's license or passport) and (5) a copy of the ID used.

We asked two professors and authors of ALM’s Tax Facts with opposing political viewpoints to share their opinions about whether the new beneficial ownership reporting obligations should be delayed.

Below is a summary of the debate that ensued between the two professors.