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CTA BOI Survey for All

Forum|Forum|1 year ago
September 5, 2024
12 replies
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Just wondering what you all are going to do since we are approaching the deadline here in four months I believe. From what I have seen myself on forums it looks like most CPAs and tax professionals are apparently not going to prepare this, but I may be wrong. I am leaning against it as of now. The 30-day provision to notify when there are changes I believe, the steep ridiculous penalties, and apparent reluctance of some insurance companies to cover this, are just three of the factors that are discouraging me from getting involved with this. If I do not get involved with this then I will be sending a letter out to business clients letting them know that they are responsible for this. If I did get involved with it then I would prepare an iron clad engagement letter separately for this CTA/BOI so I would not be responsible for any penalties. What are all of you guys and girls going to do? Thanks.

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Best answer by PATAX

Thank you to all for responding. Each will have to make his or her own decision on what they feel is best. And that is the best answer.

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BobKamman

Level 15

Thanks to an email newsletter from James Counts, California CPA, for this bulletin:

A provision for a one-year delay in BOI reporting has been included in the Continuing Resolution (CR).

The relevant language is on page 233 of the bill text using the pdf page number. Here is the link to the entire document:

https://docs.house.gov/billsthisweek/20241216/CR.pdf.

To find any information in the bill (such as this section on page 233 you can hit control F and then in the search box that comes up enter your term you would look for in the bill.

SEC. 122. EXTENSION OF FILING DEADLINE FOR CERTAIN PRE-EXISTING REPORTING COMPANIES.

Section 5336(b)(1)(B) of title 31, United States Code, is amended by striking ''before the effective date of the regulations prescribed under this subsection shall, in a timely manner, and not later than 2 years after the effective date of the regulations prescribed under this sub section,'' and inserting ''before January 1, 2024, shall, not later than January 1, 2026,''.

Before this change it reads:

(B) Reporting of existing entities.-In accordance with regulations prescribed by the Secretary of the Treasury, any reporting company that has been formed or registered before the effective date of the regulations prescribed under this subsection shall, in a timely manner, and not later than 2 years after the effective date of the regulations prescribed under this subsection, submit to FinCEN a report that contains the information described in paragraph (2).

After the change it reads:

(B) Reporting of existing entities.-In accordance with regulations prescribed by the Secretary of the Treasury, any reporting company that has been formed or registered before January 1, 2024, shall, not later than January 1, 2026, submit to FinCEN a report that contains the information described in paragraph (2).

T

Terry53029

Intuit Community Champion

This is from Spidell of CA.

SPIDELL

Tax • Analysis • Education

Congress proposes one-year delay in BOI reporting requirements for most businesses (12-18-24)

Tucked away in the proposed 1,500-page continuing resolution (CR) that Congress is hoping to pass this week is a one-year delay in the January 1, 2025, beneficial ownership information (BOI) reporting deadline for those entities subject to the BOI reporting mandate that were in existence prior to January 1, 2024. (CR Title V, Subtitle C, §122) It is unclear at this stage whether the CR will pass in its current form.

If this provision is enacted as currently proposed, it would not impact the requirement that entities subject to the mandate that are formed in 2024 file their initial report within 90 days of formation and those entities formed after 2024 file their reports within 30 days of formation. However, the preliminary injunction put in place by the U.S. District Court in East Texas has put these requirements on hold, at least for now.

IRonMaN

Level 15

The stupid elected turds seem to struggle on how just to keep the government doors open these days. Maybe if they passed laws that dealt with one item at a time instead of packing every piece of legislation with some other side deal to make a couple of other elected dufuses happy the country might be better off. But then again, they would never pass a single law because common sense doesn't exist in Washington.

Slava Ukraini!

BobKamman

Level 15

@IRonMaN Some states have a "single subject" rule for any bills that require a vote. Sometimes it's difficult to define how broad the subject can be. There is something to be said for that, but there is something to be said for the horse trading that leads to numerous ornaments on the Christmas tree. When the President is not elected with 50% of the vote, does the majority who voted against him deserve a few concessions?

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