On December 23, 2024, the United States Court of Appeals for the Fifth Circuit lifted a nationwide preliminary injunction on enforcement of the Corporate Transparency Act (CTA), which had been issued by the United States District Court for the Eastern District of Texas on December 3, 2024.  Accordingly, the CTA BOI reporting requirements and deadlines are once again in effect. 

The Corporate Transparency Act presents a significant opportunity for accounting firms.

Well-prepared accounting firms can enhance their current client engagements and grow their client base if they take advantage of the opportunity presented in the Corporate Transparency Act and Beneficial Ownership Information reporting requirements.

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Professional viewing corporate transparency act reporting requirements outlined by CT Corporation

Frequently asked questions about Beneficial Ownership Information reporting

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What is a Beneficial Ownership Information report?
Part of the Corporate Transparency Act passed by Congress in 2021, the Beneficial Ownership Information (BOI) report is a new, federally required report where individuals who directly or indirectly control a company have to identify themselves.
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Who has to file a Beneficial Ownership Information report?
The requirement is rather broad and far-reaching, and it's not always clear who will need to file. FinCEN - the U.S. Department of Treasury's Financial Crimes Enforcement Network -  estimated 32.6 million entities will be required to comply in 2024 alone.
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When is the required filing date for BOI reports, and how do we file?
 In light of a recent federal court order, reporting companies are not currently required to file beneficial ownership information with FinCEN and are not subject to liability if they fail to do so while the order remains in force. However, reporting companies may continue to voluntarily submit beneficial ownership information reports.
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How will BOI reporting requirements impact accountants?
Tens of thousands of accounting firms will be impacted by the new requirements, and there are two scenarios that accounting professionals and firms need to consider in regard to BOI reporting compliance. Namely, firm compliance and client compliance.

Next steps for your firm and your clients

Is your company required to file a beneficial ownership report? What about your clients?
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Corporate Transparency Act Resources:
Read: CTA ruled unconstitutional: What it means for BOI reporting
Read: What client information will firms need to file for them?
Watch the webinar: Navigating BOI Compliance

Additional Beneficial Ownership Information resources

What public accounting firms and accounting professionals need to know about the Corporate Transparency Act and Beneficial Ownership Information Reporting.
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The CTA presents significant opportunities for accounting firms.
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Exterior of the U.S. Department of the Treasury, whose FinCEN bureau will impose beneficial ownership information reporting requirements for business entities.
FinCEN issues Corporate Transparency Act reporting requirements.
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Small accounting firms are subject to BOI reporting requirements.
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Countdown to compliance: What to know about Beneficial Ownership Information
eBook: Beneficial Ownership Information Reporting for Tax & Accounting Professionals
Beginning in 2024 all domestic and foreign reporting companies will have to file a Beneficial Ownership Information (BOI) report with the Financial Crimes Enforcement Network (FinCEN) established under the Corporate Transparency Act. 

This ebook will help you determine if an entity is a reporting company, identify the information that you will have to report in the initial BOI report, and understand key definitions and dates.
Download the eBook

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Wolters Kluwer is not a law firm and cannot provide legal advice, including providing advice as to whether any specific entity will be required to file a report. Wolters Kluwer cannot provide its own interpretation of the statute or FinCEN’s final report ruling, however many of the questions can be answered by referring to the text of the final rule, sections of which have been provided where appropriate. You can also direct questions to FinCEN. The phone number of the FinCEN Regulatory Support Section is 1-800-767-2825 and you can email them at [email protected].
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