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A new federal requirement for legal entities was recently put into place by the US Department of the Treasury, which relates to the beneficiary ownership information of said legal entities. This affects anyone who owns a legal entity, whether you are a licensed professional or not, and includes all assumed names or “doing business as” (aka DBAs) that have been filed with any state. Again, as this is a federal requirement, this applies across all the states. Per the requirement, all owners need to provide their beneficiary information, effective as of January 1 2024.

So the real question is: What is this new federal requirement regarding beneficial information and how did it come about?

In 2021, Congress passed the Corporate Transparency Act on a bipartisan basis. This law created a new beneficial ownership information reporting requirement as part of the US government’s efforts to make it harder for bad actors to hide or benefit from ill gotten gains through shell companies, or other opaque ownership structures. 

When you file this beneficial ownership information, what the owners are providing is the the tax ID of the legal entity, the full name of the legal entity or the DBA, the address of the legal entity, and the full name and residential address of all the owners of the legal entity, including their date of birth and proof of a government issued ID, which could be a driver’s license or passport. There is no financial information required for the owners.  

Reporting Requirement

The most important part to understand about this requirement is when do you, the owner of the legal entity, need to report and file this information?  For all legal entities or DBAs that have been in existence prior to January 1, 2024, the filing does not need to be completed until December 31, 2024. Now, if you form a legal entity or a DBA on or after January 1, 2024, you have only 90 days after the formation of the new legal entity or DBA to complete the filing of the beneficial ownership information. 

Since the enactment of this federal requirement, there have been several lawsuits brought challenging whether providing this information is considered unconstitutional.  To date, nothing has been ruled that affects all of the United States, so as of the date of this newsletter, every owner must provide their information, as indicated above, by the required dates.  


If you have any questions about this, please visit https://www.fincen.gov/boi-faqs.If you want to report your information directly online, you can use the following link:  https://boiefiling.fincen.gov/fileboir. Should you have any questions, you can reach out to your accountant or attorney, who can provide more information for you.