As part of our commitment to keeping you informed, we want to make sure you're aware of important updates regarding business filing requirements. Staying compliant with these regulations is essential to avoid penalties and ensure your business remains in good standing.
Most business entities with fewer than 20 full-time employees and less than $5 million in sales or gross receipts, as reported on federal tax returns, will likely be required to complete the BOI disclosure.
While Brinker Simpson & Company does not directly manage Beneficial Ownership Information (BOI) filings, we are here to provide you with the necessary resources and information to help you comply with these critical regulations.
A Timeline to Help You Prepare for Beneficial Ownership Information Reporting
If your company is required to file a Beneficial Ownership Information (BOI) report by January 1, 2025, you might be asking yourself, "When do I need to start preparing?" Like other regulatory requirements, it's best to begin data collection and preparation as early as possible. While there have been some appeals to the ruling, the timeline has not changed.
For businesses with complex structures, such as multiple entities or owners, or if tracking down individuals is necessary to gather all the required information, additional time and preparation may be needed to meet the filing deadline. Below is an overview of where you should be now and what you need to accomplish by the end of the year.
What Should You Have Already Completed for BOI Reporting?
By now, your company should have started compiling and reviewing a comprehensive list of the information required for BOI reporting. This includes working with advisors to determine which entities and individuals are required to file or are exempt and deciding who will be responsible for filing. In complex structures, you may need to consult with a legal advisor. Depending on your situation, you may be able to handle the filing internally. However, seeking external assistance might benefit businesses with multiple entities or owners, especially if you are short on resources.
What Should You Be Doing for the Rest of the Year to Prepare for BOI Reporting?
Below is a sample timeline to help keep you on track through the end of the year. Please note this timeline does not apply to entities formed in 2024, which must file within 90 days of formation. Starting in 2025, new entities must file within 30 days of formation. Any changes to your BOI filing must also be submitted within 30 days.
Sample Timeline
July – August: Request FinCEN IDs for each reporting company and beneficial owner. While not required, a FinCEN ID can simplify the filing process. If you're not using a FinCEN ID, gather all necessary information, such as legal addresses, names, EINs, and beneficial owner details (copy of ID, address, date of birth, etc.). This is the reporting company's responsibility.
September – October: Prepare and submit the information. Decide whether to use the PDF format or the online portal and complete the filing. Depending on the complexity, the reporting company, a legal adviser, or an accounting advisor may handle this.
November – December: Monitor any changes to your submitted BOI data. If changes occur, you must submit an updated report within 30 days. The reporting company is responsible for monitoring changes. If a third party filed your initial report, you will need to send the updated information to them so they can file a revised BOI report on your behalf within the required timeframe.
Important Tips for Filing
Real-time submission: Web-based filing must be completed and submitted in real time. You cannot save and return to your submission later, so ensure all necessary information and documents are ready before starting the process.
Required documentation: Unless you provide a FinCEN ID, you must submit an electronic image of an acceptable identification document for each company applicant and beneficial owner.
Acceptable identification documents include:
- State-issued driver's license
- State/local/tribal-issued ID
- U.S. passport
- Foreign passport (only if no other identifying documents are available)
The document must be non-expired, and the image must be clear and readable, including the page or side with the unique identifying number and other data. Supported file formats include JPG/JPEG, PNG, and PDF, with a maximum file size of 4 MB per image.
Due to size restrictions, your safest bet is to have the required documentation in PDF format.
Deadlines to Remember and Helpful Links
Existing companies (as of January 1, 2024)
↪️File by January 1, 2025.
New companies (registered between January 1, 2024, and January 1, 2025)
↪️File within 90 days of formation.
New companies (registered after January 1, 2025)
↪️File within 30 days of formation.
🔗 E-File Online Step-by-Step Instructions
How Brinker Simpson Can Help
Remember, while we do not facilitate BOI filings, we are here to keep you informed and provide valuable resources. Don't hesitate to contact our team if you have any questions or need assistance understanding these requirements.