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Beneficial Ownership Interest (BOI) reporting through FinCEN

Law changes related to Beneficial Ownership Interest (BOI) reporting through FinCEN.

You may have received an email from the Arizona Corporation Commission regarding law changes related to Beneficial Ownership Interest (BOI) reporting through FinCEN. This requires owners of entities registered with the Arizona Corporation Commission or Secretary of State or with any similar government body in another state to register as a beneficial owner with FinCEN, a Federal government agency. 

Entities which were created or registered prior to January 1, 2024 must report to BOI before January 1, 2025.  Entities created or registered during 2024 will need to report to BOI within 90 calendar days after receiving notice that your entity's creation or registration is effective.

We will not be addressing BOI reporting for our clients until this summer as several issues are unresolved at this time. 

There is concern amongst the CPA community that assisting clients with FinCEN reporting may be the practice of law. We are waiting for the insurance companies and the AICPA to resolve this issue. 

The House of Representatives has passed a bill to delay the filing requirement for existing entities until December 31, 2025. The Senate has not yet acted on the bill.

A Federal District Court has a case before it regarding the Constitutionality of the Corporate Transparency Act which creates the BOI reporting.  

Again, at this time, you have until December 31, 2024 to make your initial filing.