by Prof. Robert Bloink and Prof. William H. Byrnes
For most business entities, the deadline for compliance with the FinCEN beneficial ownership information (BOI) reporting obligations is right around the corner. Starting in 2025, nearly all business entities will be required to report certain information to FinCEN—a new and controversial requirement created under the Corporate Transparency Act (CTA) of 2021. Many business owners have significant questions about their upcoming reporting obligations. Other small business clients may have no idea that the reporting obligation exists. Penalties for willful violation of the BOI reporting rule are steep--$591 per day—and the government hasn’t been entirely clear as to when a violation will be considered “willful”. That makes it critical that small business clients understand their reporting obligations and the deadline that applies to their business.
FinCEN BOI Reporting: Background