Author Ownership Data (AOD): A Comprehensive Guide
Foreign entities registered to do business in the United States (foreign reporting companies) are required to report beneficial ownership information (BOI) to the Financial Crimes Enforcement Network (FinCEN). This article provides a clear and straightforward guide on who needs to report, what information needs to be provided, and the deadlines for filing the BOI report.
Who must report
Foreign reporting companies are the entities that fall under this requirement. If you are a foreign entity formed under the laws of a foreign country and registered to do business in a U.S. state or tribal jurisdiction, you are required to comply with the BOI reporting rules.
What to report
The BOI report should only include beneficial owners of the foreign entity who are not U.S. persons. U.S. persons who are beneficial owners do not need to be reported. If all beneficial owners are U.S. persons, the foreign entity does not need to file a BOI report.
Deadlines
The deadline for foreign entities to report BOI is April 25, 2025, for those registered before March 26, 2025. Entities registered after March 26, 2025, must file their BOI reports within 30 days of registration.
Where to report
The BOI E-Filing website is where you go to file the report. It's essential to ensure that you are using the correct platform for your filing.
Exemptions
U.S. companies and U.S. persons, as well as U.S. persons owning interests in foreign entities, are exempt from BOI reporting under the Corporate Transparency Act according to the interim final rule effective March 26, 2025. This rule significantly narrows the BOI filing requirements, focusing exclusively on foreign reporting companies registered in the U.S.
Additional Information
- Sole proprietor authors in the United States are not impacted by BOI.
- The Corporate Transparency Act (CTA) made beneficial ownership information reporting a requirement by law on January 1, 2021.
- A 5-minute video is available to guide you through the BOI reporting process step by step.
- If you "willfully" ignore the BOI reporting rules, you could face a daily fine of $500 (currently $591 due to inflation).
- Violating BOI reporting requirements could also lead to up to two years of federal prison and a $10,000 fine.
- Foreign companies registered to do business in any U.S. State or Tribal jurisdiction are impacted by BOI.
- If your foreign sole proprietorship was registered to do business in the United States by filing a document with a secretary of state or similar office, you're still impacted by BOI reporting.
Optional steps
- Optionally, you can create a FinCEN ID to simplify the reporting process.
- There's no filing fee for BOI reporting.
- Now, only foreign entities registered to do business in the U.S. must report BOI.
To stay informed about changes in BOI reporting, you can sign up for FinCEN updates via email or text. It's essential to keep yourself updated to ensure compliance with the ever-evolving regulations.
- For foreign entities, it's crucial to understand that if you are registered to do business in a U.S. state or tribal jurisdiction, you need to comply with the Beneficial Ownership Information (BOI) reporting rules in the context of finance and business, as required by the Financial Crimes Enforcement Network (FinCEN).
- In terms of the BOI report, it should only be submitted by non-U.S. beneficial owners, while U.S. persons who are beneficial owners are exempt from this reporting process, as per the Corporate Transparency Act's guidelines.
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