Beneficial Ownership Information (BOI) Reporting

Update March 24: FinCEN issues interim final rule to remove BOI filing requirements for U.S. companies and persons

Update March 3:  Treasury Department suspends enforcement of BOI and Corporate Transparency Act

Update Feb. 28:  FinCEN will extend March 21 BOI reporting deadline and temporarily suspend enforcement.

Update Feb. 26: Information is changing rapidly as court challenges and legislation is introduced regarding the mandate of beneficial ownership information reporting. FinCEN is now requiring BOI reports to be filed by March 21, 2025 for most companies.

Update Feb. 19: Injunction stopping BOI filing requirements is lifted; FinCEN promises a 30-day filing delay

As the landscape of financial regulations continues to evolve, the Indiana CPA Society is your advocate amid ongoing changes. The Beneficial Ownership Information (BOI) reporting requirements, which were set to take effect on January 1, 2024, under the Corporate Transparency Act, raised 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. However, the filing due date has been challenged in court, been extended and is being legislated by Congress, creating constant fluctuations in the current due date.

Please visit AICPA's BOI resources website and FinCen's BOI webpage to ensure you are checking the most current information.

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 (12/4/24)
• INCPAS signs on to AICPA Letter to Congress: Recent BOI court ruling confuses businesses — FinCEN enforcement should be delayed (4/10/24)
• AICPA Letter to Congress: BOI rule should be suspended until information is widely available and questions have been answered (2/14/24)
  

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

• FinCEN issues interim final rule to remove BOI filing requirements for U.S. companies and persons (March 2025)
• Treasury Department suspends enforcement of BOI and Corporate Transparency Act (March 2025)
• Injunction stopping BOI filing requirements is lifted; FinCEN promises a 30-day filing delay (February 2025)
• Supreme Court lifts injunction preventing enforcement of CTA and BOI requirements (January 2025)
• 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) (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