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The compliance brief: the BOI report is back

Beneficial ownership reporting, who it applies to now, and the deadline foreign owners shouldn't sleep on.

The March brief is a single big topic, because it earned it: beneficial ownership (BOI) reporting.

What it is

BOI is filed with FinCEN, not the IRS, and answers one question: who owns and controls this company? A reporting company identifies its beneficial owners — broadly, anyone who owns 25%+ or exercises substantial control — by name, date of birth, address, and an ID document.

Why we say “it’s back”

This rule has whiplashed. Deadlines, exemptions, and even whether some companies must report at all have changed more than once. That history is exactly why it’s dangerous: people who tuned out during an off period can miss a reinstated deadline.

What foreign owners should do

Living abroad doesn’t exempt you — a nonresident owner of a U.S. reporting company is still a beneficial owner. Confirm the rule currently in force, file if you’re a reporting company, and keep the confirmation in your record book. The penalties for willful non-reporting are steep and accrue daily.

We track the current status and surface it on your dashboard, so “is this on right now?” isn’t a question you have to chase.

The compliance brief

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