Beneficial Ownership Information (BOI) Reporting

Update Dec. 5: Federal district court injunction suspends implementation of BOI reporting requirements

As the landscape of financial regulations continues to evolve, the Indiana CPA Society is your advocate amid upcoming changes. The Beneficial Ownership Information (BOI) reporting requirements, set to take effect on January 1, 2024, under the Corporate Transparency Act, raise important considerations for businesses across the United States. This legislation mandates the reporting of beneficial owners and company applicants, a process that can significantly impact CPAs and the clients they serve.

The Indiana CPA Society is committed to helping CPA firms and the small businesses that rely on their expertise. Recognizing potential challenges, we seek a fair and smooth transition. We champion a reasonable implementation approach, benefiting both CPAs and clients.

INCPAS takes the lead in advocating for you. We endorse legislative efforts like S. 2623, the Protecting Small Business Information Act of 2023, that would extend the reporting due date from 1/1/24 to 1/1/25 to allow time for members and affected businesses time to understand the requirements and comply. This approach grants CPAs the time needed to prepare, educate clients, and minimize disruptions.

Recent Advocacy Efforts on Your Behalf

• INCPAS, other state societies and AICPA will continue to advocate for minimum January 1, 2026 filing extension for BOI filings (12/4)
• INCPAS signs on to AICPA Letter to Congress: Recent BOI court ruling confuses businesses — FinCEN enforcement should be delayed (4/10)
• AICPA Letter to Congress: BOI rule should be suspended until information is widely available and questions have been answered (2/14)
  

Recorded Resource

In case you missed the live In the Know session, we recorded this event for you to watch. While watching the recording now does not count for CPE, there is a lot of great information to take away.

• [Recording] Beneficial Reporting Requirements: Why Virtually Every Small Client is Ensnared in the New Law (August 2023)
• [Slides] Beneficial Reporting Requirements: Why Virtually Every Small Client is Ensnared in the New Law (August 2023)

Additional Resources & Related CPE

• BOI reporting deadline extension proposed in House draft budget bill (December 2024)
• BOI Reporting: Most recent notices from FinCEN (December 2024)
• BOI requirements continue despite concerns (August 2024)
• CAMICO's Corporate Transparency Act coverage and considerations for firms (February 2024)
• Alert: BOI filing scam letter example (February 2024)
• What accounting firms need to know about the Corporate Transparency Act | AICPA (cpai.com) (January 2024)
• BOI reporting and unauthorized disclosure penalties increase (January 2024)
• The Corporate Transparency Act & CPA Firms (January 2024)
• Sign Up for FinCEN's Updates (January 2024)
• S Corps Corporate Transparency Act Slides
• Sample Language for Engagement Letters
• The Corporate Transparency Act: A Primer for Indiana CPAs
• INCPAS President & CEO Courtney Kincaid's Beneficial Ownership Segment from Wish-TV
• FinCEN's Small Entity Compliance Guide for BOI reporting requirements
• AICPA's BOI reporting resources