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Beneficial Ownership Information (BOI) reporting requirements and updates

Updated: Apr 29


UPDATE AS OF MARCH 21, 2025: FinCEN Removes Beneficial Ownership Reporting Requirements for U.S. Companies and U.S. Persons, Sets New Deadlines for Foreign Companies


WASHINGTON––Consistent with the U.S. Department of the Treasury’s March 2, 2025 announcement, the Financial Crimes Enforcement Network (FinCEN) is issuing an interim final rule that removes the requirement for U.S. companies and U.S. persons to report beneficial ownership information (BOI) to FinCEN under the Corporate Transparency Act.


In that interim final rule, FinCEN revises the definition of “reporting company” in its implementing regulations to mean only those entities that are formed under the law of a foreign country and that have registered to do business in any U.S. State or Tribal jurisdiction by the filing of a document with a secretary of state or similar office (formerly known as “foreign reporting companies”). FinCEN also exempts entities previously known as “domestic reporting companies” from BOI reporting requirements.


Thus, through this interim final rule, all entities created in the United States — including those previously known as “domestic reporting companies” — and their beneficial owners will be exempt from the requirement to report BOI to FinCEN. Foreign entities that meet the new definition of a “reporting company” and do not qualify for an exemption from the reporting requirements must report their BOI to FinCEN under new deadlines, detailed below. These foreign entities, however, will not be required to report any U.S. persons as beneficial owners, and U.S. persons will not be required to report BOI with respect to any such entity for which they are a beneficial owner. For more information, see https://fincen.gov/news/news-releases/fincen-removes-beneficial-ownership-reporting-requirements-us-companies-and-us.


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UPDATE AS OF MARCH 5, 2025: Effective immediately, LLCTLC will no longer file BOI reports on behalf of clients. Department of Treasury put out the following statement 3/2/25: "The Treasury Department is announcing today that, with respect to the Corporate Transparency Act, not only will it not enforce any penalties or fines associated with the beneficial ownership information reporting rule under the existing regulatory deadlines, but it will further not enforce any penalties or fines against U.S. citizens or domestic reporting companies or their beneficial owners after the forthcoming rule changes take effect either." Thus, while the reporting requirements are still technically 'in effect,' there will be no penalties for non-compliance.


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UPDATE AS OF FEBRUARY 25, 2025:

If you have already filed a BOI report, no further action is needed, unless changes have been made to your LLC. If changes have been made to your LLC since you filed the BOI report, you have 30 days to update your BOI report.


Beneficial Ownership Information (BOI) reporting requirements have been reinstated. As of yesterday's ruling, a Beneficial Ownership Information Report must be filed by March 21, 2025.  You may file the reports yourself, OR we can file them on your behalf.


If you would like LLCTLC to file on your behalf:

We charge a service fee of $115 per BOI Report. Complete and return a BOI Request Form.  Email the forms back to support@llctlc.com, and attach a clear picture or scan of each beneficial owner's identification. (Drivers' License or Passport are most commonly used).  



To file the BOI reports yourself:

Instructions on completing this BOI report can be found here. 


To file this report, you will be required to provide the following information:

  • The LLC name and address

    • Montana LLC: 415 North Benton Ave, Helena MT 59601

  • The Tax Identification Number 

    • This can be an EIN or Social Security Number (SSN)

    • Email support@llctlc.com for more information on obtaining an EIN.

  • If your entity was established January 1, 2024 or later, you will need to provide a  Company Applicant FinCEN ID number. We provided this in a follow up email when you first signed up (Subject: Required Beneficial Ownership Information Report). If you cannot find that information, please contact support@llctlc.com.

  • For each beneficial owner, you will need to provide the following information:

    • Full name

    • Residential address 

    • Date of birth

    • Copy of Identification (ie. driver's license, passport, etc) 

    • If any of the above information changes, you must file an updated BOI report within 30 days. 

  • You are welcome to email us a copy of the completed report. We can upload that to your client portal for your future reference.


Please consult your accountant if you have specific questions about your entity's BOI report.



 
 
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