Overnight
BOIR Refresher
Let’s review the finer points of Beneficial Ownership Interest Reporting (BOIR). BOIR is what tax professionals affectionately call the “Hey, Drug Dealers & Money Launderers! The Government Says, “Don’t Use an LLC to Do Criminal Stuff!” law.
It's difficult to describe the true (evil) purpose of this law other than surveillance and leverage/selective enforcement. It would solve zero crimes other than the crime it creates because 80% of businesses and organizations not being compliant within 24 months and facing tens of thousands in penalties each.
The law is part of the Corporate Transparency Act. It requires all individuals who own or influence nearly any entity registered with a state agency (such as HOAs, corporations, and LLCs) to provide and regularly update highly personal information with FinCEN, a Treasury Department agency. Failure to register or promptly update each owner or influencer’s personal information can be punished by a $600+ daily penalty and/or jail time!
For more info on the BOIR drama, check out these articles:
BOIR Returns – Announcement Number One
OK, let's get back to the announcement. Here's an excerpt from the subscription service statement we received:
February 21, 2025 - The nationwide injunction prohibiting enforcement of the Corporate Transparency Act (CTA) has been stayed, meaning FinCEN will resume enforcement of the required beneficial ownership information (BOI) filings.
Simply put, the BOIR filing requirements are reinstated. FinCEN has issued a notice that resets the filing deadline for most companies to March 21, 2025.
But Wait, There's More!
BOIR Reversal-Reversal – The Body Slam-A-Roo
The reinstatement of Beneficial Ownership Reporting was upsetting, primarily because, ...well, you read why a few paragraphs ago. However, being as busy as we are, there was little time to dwell on the topic, let alone share it in a newsletter. Then, a few days ago, we received the following directly from FinCEN:
WASHINGTON––Today (2-27-25), FinCEN announced that it will not issue any fines or penalties or take any other enforcement actions against any companies based on any failure to file or update beneficial ownership information (BOI) reports pursuant to the Corporate Transparency Act by the current deadlines. No fines or penalties will be issued, and no enforcement actions will be taken until a forthcoming interim final rule becomes effective and the new relevant due dates in the interim final rule have passed.
Then, several days after this release, President Trump made the following announcement on Truth Social:
So, is Beneficial Ownership Interest Reporting finally a fading nightmare? It looks like it is, at least until 2028!
All courses and articles are for informational purposes only and do not constitute tax advice. Taxes are complicated - do not act on course information without consulting a professional. Always refer to treasury regulation before making any tax decision. Read the full disclaimer.