Should we offer BOI compliancy?

[joggergirl123]

Should accounting firms offer BOI registration to corporations as of January 1?

[Terry53029]

I don't think so, as that is a legal item. I plan on telling my clients, but they will have to fill out the form themself

[BobKamman]

That horse is not yet dead, but it has already been flogged extensively in this thread:

https://accountants.intuit.com/community/proseries-tax-discussions/discussion/boi-question/00/276154 

[Jim-from-Ohio]

Looks like the extension was passed. just received this email from FCEN

You are subscribed to FinCEN Updates. The information below is available at Fincen.gov.

U.S. Beneficial Ownership Information Registry Now Accepting Reports

Today, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) began accepting beneficial ownership information reports. The bipartisan Corporate Transparency Act, enacted in 2021 to curb illicit finance, requires many companies doing business in the United States to report information about the individuals who ultimately own or control them.

Filing is simple, secure, and free of charge. Beneficial ownership information reporting is not an annual requirement. A report only needs to be submitted once, unless the filer needs to update or correct information. Companies that are required to comply must file by the following deadlines:

• Reporting companies created or registered to do business in the United States before January 1, 2024 must file by January 1, 2025.
• Reporting companies created or registered to do business in the United States in 2024 have 90 calendar days to file after receiving actual or public notice that their company’s creation or registration is effective.

To find out more about the reporting process, visit https://www.fincen.gov/boi.

News Release: https://www.fincen.gov/news/news-releases/us-beneficial-ownership-information-registry-now-accepting...

[PATAX]

@Jim-from-Ohio Jim, I just received that also. What happened to the Bill in the senate that you mentioned a couple of weeks ago? Thanks.

[Jim-from-Ohio · Accepted solution]

@PATAX i think that bill was the one extending it to prior companies until 01.01.25 and companies new in 2024 have 90 days. i am glad to see in that email it is a one time filing (unless changes prompt another filing).  I am leaning on just doing this for my clients. I was undecided before but my clients are going to look to me to handle this, even though it is not a tax return per se it is perceived as such maybe. 

[PATAX]

@Jim-from-Ohio Yeah we have a whole year for existing clients, and like Iron Man said I am going to see what develops with this. 

[Jim-from-Ohio]

on second thought.. I may direct clients to do this.. (in the summer for pre 2024 clients as I just read you have to upload photo ID, from a facebook post, not from me personally:

I just filed BOI report for my own PC. Took about 20 minutes. Of course I had all of the info ready and I am the only beneficial owner. You have to have an image of your ID. You have 2 choices for submission 1) On-line PDF which you can save and upload when completed. Requires Adobe Reader 8 or higher. 2) You can fill-in an online report and submit that. After you submit it you can download your copy and confirmation. Expiration of your ID does not trigger filing requirement as long as only the expiration changes. Document ID change or name or address change does trigger re-filing.

[Jim-from-Ohio]

or i ask client to email me jpeg of their drivers license and I will file it.. not sure yet.. the pressure is off for pre 2024 clients though as of now, and maybe this gets totally abolished, which i doubt though. working on some business clients today for 2023.. how ProSeries handles fixed assets is awesome.. just prepared an S Corp 2023 return with about 35 fixed assets.. no new additions in 2023.. bam.. the number was right there for the 2023 depreciation expense.  booked the entry in sage and prepared the 1120S.. 18 minutes for an S Corp return!. thank you Intuit ProSeries

[jeffmcpa2010]

I am not sure these dates are any change, Existing entities have had the entire year of 2024 to file, in all the previous articles I have seen.

I am in the "I am not doing it" camp, but will attempt to notify clients when I know they have relevant entities.

[BIGPETE]

Are tax preparers required to file a BOA  if we are just a DBA and not an LLC?

[SDDREW]

Fincen website has useful FAQ for reporting companies https://www.fincen.gov/boi-faqs#B_7 

[Strongsilence-CPA]

AON insurance (AICPA provider) does not appear to cover BOI work for CPAs.  I say 'appear' because I have not called them yet to verify. But, I know there is a disclaimer paragraph in their standard letter.

What is the policy of your insurance provider?

[Strongsilence-CPA]

@joggergirl123 

She started a good conversation. Thank you. I bookmarked this for future reference.

I think I will be offering BOI/CTA work for clients. I'm going to talk with a local business attorney who I trust to see if he would like the complicated BOI clients. I look forward to an attorneys perspective.

Spidell in CA does not think this is legal work and I respect that opinion.