BOI

Nov 19, 2024

From Dust to Transfer

 

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:
 
  1. Do you own 25% or more of a US entity (company or organization)?
  2. 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:

  1. File it yourself. It is not so complicated. See https://boiefiling.fincen.gov/
  2. Engage CW Tax. Please submit all documents no later than Dec 1, 2024.
    1. Engagement letter (download here: https://cloud.colewaxman.com/dl/Ul0C5jhBjA)
    2. List of all stakeholders. Include their percentage ownership and roles in the company.
    3. 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. 
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Many taxpayers receive identity verification notices from the IRS, and in most cases, the process is straightforward and can be resolved without much difficulty.

You have the following options to verify your identity:

Option 1: Verify through the IRS using your ID.Me account

 

Option 2: Use the IRS Document Upload Tool

    • Please note when they ask for the access code answer "no" and put in the notice/letter type 5447C

    • Alternatively, we can upload the documents on your behalf. (Please note additional fees apply.)

For both options 1 and 2:

    1. Allow at least 30 days to process.
    2. You can then check your status on IRS Where's My Refund or request that we pull your transcript.

    Option 3: Call the IRS

      1. Phone number: 1-267-941-1083

      1. When calling the IRS please note that there could be long wait times. We recommend the best time to call is as close to 1PM Israel time as possible, when the lines first open.

    When speaking with the IRS agent:

      • Let them know you are calling in response to a Letter 5447C letter for tax year 202x.

      • Provide the control number as it appears on the first page of the letter.

      • Be prepared to answer any question they ask from the first 2 pages on both tax returns, including:

          • complete address

          • filing status (Head of Household /Married Filing Separately / Married Filing Joint/ Single)

          • refund amount.

      • If you are unsure of an answer you may ask the agent where it can be found on the return.

      • Know the dates of birth for you and the children on the return

      • Know your mother's maiden name

      • If they ask about W-2 income, tell them since you live outside of the US your income isn’t reported on a W-2, but rather the equivalent form 106 instead.

    They hopefully will not ask any more financial questions.

    If your identity is successfully verified during the call, the IRS will typically inform you immediately. Your refund should then be released within approximately 6-9 weeks.

    Documents Required in All Cases

    Regardless of the verification method you choose, you will need:

      • a copy of the 5447C letter you received

      • the first 2 actual 1040 pages of your 202x and 202x tax returns

    Additional Documents for ID.me or Document Upload Verification

    If you are verifying online through ID.me or using the IRS Document Upload Tool, you will also need:

    Two clear copies of acceptable identification, as listed in the IRS letter (for example passport and license).