Beneficial Ownership Information (BOI)
This is a new compliance requirement (with gratitude and blessings to our elected representatives in Washington D.C.). It doesn’t apply to most of our clients. We’re going to over-simplify a bit for your convenience, but if you would like the full bureaucratic details, then visit this site: https://www.fincen.gov/boi-faqs.
If you answer “yes” to either of these questions, then you probably need to file this report:
- Do you own 25% or more of a US entity (company or organization)?
- Are you a senior officer or important decision maker for a US entity?
The most common scenario for our clients is real estate investors that manage their real estate via one or more US based LLC’s.
When does this need to be filed?
No later than Dec 31, 2024, for entities established prior to Jan 1, 2024. If you established a US company after this date, then the deadline is date of establishment plus 90 days.
If you need to file the “BOI”, then you can:
- File it yourself. It is not so complicated. See https://boiefiling.fincen.gov/
- Engage CW Tax. Please submit all documents no later than Dec 1, 2024.
- Engagement letter (download here: https://cloud.colewaxman.com/dl/Ul0C5jhBjA)
- List of all stakeholders. Include their percentage ownership and roles in the company.
- Clean copy of your passport(s) (US or Israeli). It must be valid for plus 6 months. Please scan with a proper scanner (rather than your phone). Go to Office Depot if you don’t have a scanner.
The above is not legal advice. If you have any concerns then please schedule a consultation and/or refer to https://www.fincen.gov/boi-faqs.