FINCEN Requirements - NOW YOU CAN IGNORE

HOPEFULLY, THE FINAL UPDATE (8/2026): The Financial Crimes Enforcement Network (FinCEN) will issue a final rule (RIN 1506–AB67) that permanently removes the requirement for U.S. companies and U.S. persons to report beneficial ownership information (BOI) to FinCEN under the Corporate Transparency Act, Title 64 of P.L. 116‑283, the Treasury Department said Tuesday.

The final rule will:

  • Adopt the exemptions set out in the interim final rule issued in March 2025, making the rollback of beneficial ownership reporting by U.S. companies permanent.

  • Exempt U.S. persons who have obtained FinCEN IDs from any obligation to update or correct the information they originally provided to FinCEN to obtain those IDs.

  • Eliminate the requirement for foreign companies to report U.S. person “company applicants” (for example, the individuals who helped those foreign companies register to do business in the United States).

  • Exempt foreign pooled investment vehicles registered in the United States from reporting the beneficial ownership information of a U.S. person in control of the investment vehicle.

  • Confirm that FinCEN will delete information about any individuals — company applicants, beneficial owners, or recipients of a FinCEN ID — that FinCEN reasonably believes is a U.S. person (for example, information linked to a U.S. passport or U.S. driver’s license).

If you delayed filing your BOI report, it will not be required unless a future administration or Treasury Department reverses this decision.

If you already filed a BOI report, FinCEN is deleting the report and all related information to protect your identity.

ANOTHER UPDATE (3/2025): While all court cases have been concluded, FINCEN announced on 2/27/25 that they are voluntarily moving the filing deadline back to March 21, 2025 and may potentially make additional changes to the filing requirements. We still recommend that you file this form if you have not already done so.

ANOTHER UPDATE (2/2025): Due to the multiple court cases to dismiss the Beneficial Ownership Information (BOI) report, the filing original filing deadline of January 1, 2025 has been on hold. With the Federal courts filing issuing the last remaining injunction in those cases, FINCEN has moved the filing deadline to March 21, 2025. While the House has passed H.R 736, Protect Small Businesses From Excessive Paperwork Act of 2025 to extend the deadline to January 1, 2026, the bill still needs the Senate’s approval and the President’s signature. Since this would only be a delay and the filing is relatively simple, we would encourage you to file now before the March 21, 2025 deadline if you have not done so already.

UPDATE (8/15/2024): FINCEN has not back off the filing requirements or deadlines so if you have not already filed your BOI report, you need to get started today.

FINCEN (Financial Crimes Enforcement Network) needs your information

In a world-wide effort to crack down on money laundering, governments want the ability to understand who owns what. So starting in 2023, you will need to file an annual report (BOI) with FINCEN to let them know that you own your dental practice. With fines for non-reporting at $500/day with a maximum of $10,000 and two years in jail, this is not something to ignore.

Things to know:

  • FINCEN has not formally completed the BOI (Beneficial Ownership Information) form but will release those details before January 1, 2024

  • If the company was established prior to January 1, 2024, you have until December 31, 2024 to complete the filing.

  • If the company is established after January 1, 2024, you have 30 days to file the BOI report after the formation date.

  • If you own your practice building in an LLC (which you should), you will have to file a BOI report for that entity as well.

  • Since FINCEN is not the IRS, CPAs are not allowed to represent you. Therefore, you will need to work with your attorney for guidance on filing and staying compliant.

Jeff Gullickson