rbynaker
Level 13

I picked this thread because it was the most recent and easiest to find. 🙂

Someone posted this link in another tax group:

https://www.fincen.gov/boi-faqs

I've been generally of the opinion that accountants have no authority to file these.  We are granted limited authority to "practice law" in that Title 26 of the U.S. Code (commonly referred to as the Internal Revenue Code) is "law".  There is also a specific carve out for FBAR filings.  Beyond that, IMO this BOI is the practice of law.  If you scroll down on the link above to FAQ Section D you'll see this is ridiculously all-encompassing and, while some things are cut-and-dried, many of the terms are vague and poorly defined.  This might be easy enough for a SMLLC with no employees but get much beyond that and you're trying to figure out who might be an "important" decision-maker, regardless of actual/legal ownership.