UPDATE – March 3rd, 2025
The Treasury Department announced that it will not enforce penalties or fines associated with Beneficial Ownership Information and the Corporate Transparency Act. The deadline previously communicated of March 21st, 2025 will no longer be enforced.
UPDATE – February 19th, 2025
The BOI reporting requirements are back in effect following the February 18th decision by the U.S. District Court for the Eastern District of Texas in Smith, et al. v. U.S. Department of Treasury, et al. The new deadline to submit a BOI report is March 21, 2025 for most companies.
UPDATE – December 27th, 2024
The Fifth Circuit Court Of Appeals has vacated their stay of the preliminary injunction from December 23rd, 2024. Once again, enforcement of the Beneficial Ownership Information Report requirement has been halted and there is no active deadline. Please be sure to check back frequently for updates.
UPDATE – December 23rd, 2024
The US Fifth Circuit Court Of Appeals reviewed and overturned the Texas Federal Court Injunction. This action has reinstated the BOI Filing deadline of January 1st, 2025. This means all non-exempt companies formed in 2024 are required to file their report by the 1st of the new year. In light of the US Fifth Circuit Court of Appeals decision on December 23, 2024, deadline extensions are in place for qualifying reporting companies. Learn more about deadline extensions in the following FAQs.
UPDATE – December 3rd, 2024
Enforcement of the Beneficial Ownership Information Report requirement has been paused due to a Texas Federal Court injunction. This injunction is currently being appealed by the Department of Treasury.
BOI Frequently Asked Questions
What is the Beneficial Ownership Information (BOI) Report?
The BOI report is a required federal filing that newly formed businesses must submit to the Financial Crimes Enforcement Network (FinCEN). This report provides FinCEN with the name, address, and identification information for the company, its beneficial owners, and its company applicants (in the case of new businesses). The purpose of a BOI report is to help combat financial crimes in the US through increased oversight.
Who is required to File a BOI report?
The vast majority of corporations, LLCs, and similar business entities created or registered in the U.S. must file a BOI report to FinCEN. Large companies with 20+ full-time employees and $5 million in annual revenue, publicly traded companies, and a handful of other entities are exempt. If you formed an LLC to register your vehicle, then you are required to submit a BOI report.
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What Is The Deadline for Filing The BOI Report?
UPDATE [March 3rd, 2025]: The Treasury Department announced that it will not enforce penalties or fines associated with Beneficial Ownership Information and the Corporate Transparency Act. The deadline previously communicated of March 21st, 2025 will no longer be enforced.
Prior to this, the Corporate Transparency Act of 2019 (CTA) directed new businesses (formed on or after January 1, 2024) to file a Beneficial Ownership Information (BOI) report within 30 days of formation or registration. However, due to several court rulings since December 2024, BOI reporting had been extended and not enforced. On February 18th, 2025 decision the U.S. District Court for the Eastern District of Texas upheld the BOI reporting requirement with a March 21st, deadline. However, on March 3rd, 2025, the US Treasury halted enforcement of penalties and fines associated with BOI reporting and the CTA.
Can I Still File the BOI?
Yes, you can still file your BOI Report. If you’ve already hired us to handle this, we’re continuing to file for our clients. Due to the high demand as the deadline approaches, we recommend you file as soon as possible.
NEW! What’s happening with the BOI Reporting requirements?
There have been a lot of questions about the BOI reporting requirements due to a legal back-and-forth. As of of February 19th, 2025, the Treasury Department announced that it will not enforce penalties or fines associated with Beneficial Ownership Information and the Corporate Transparency Act.
We’re closely monitoring the situation and will update our FAQs as we learn more. You can still opt to file your Beneficial Ownership Information Report. If you’ve already hired us to handle this, we’re continuing to file for our clients, even though the process is slower due to limitations FinCEN has placed on submission methods.
Should I File My BOI Report Myself?
If you prefer to file on your own, you’re welcome to do so through the official FinCEN BOI Filing Portal. However, if you’ve already hired us, rest assured that we’re actively working on your filing and will handle it as soon as possible.
Will this change the vehicle registration process?
No, the BOI report does not change the vehicle registration process. This report is an additional filing for the limited liability company (LLC) under which your vehicle is owned. It is not a filing required by us or the state of Montana. The BOI report is a filing required by the federal government and this requirement applies to companies in all 50 states.
Will my information be made public?
No, the information you disclose on your BOI report is NOT public record. BOI reports are stored by the federal government in a secure online database that is not publicly available.
Are there any exemptions to filing the BOI Report?
According to FinCEN, there are several exemptions. However, we cannot advise clients on whether their specific business is exempt. We encourage clients to consult with a business advisor or attorney.
What happens if I don’t file a BOI report for my business?
Anyone who willfully violates the BOI reporting requirements—including failing to file a BOI report—could face civil penalties up to $500 for each day that the violation occurs. Note that the civil penalty amount is adjusted annually for inflation.
Criminal penalties for willfully violating the BOI reporting requirements include up to two years of imprisonment and a fine of up to $10,000.
Can I dissolve my company to avoid the BOI?
No. Even if you are active one day in 2024, you must file.
What are the filing requirements for the BOI?
Unless you have been exempt from filing, the BOI requires basic information about your company:
- Legal business name and any trade names or DBAs
- US business street address
- Formation jurisdiction
- Tax ID number (EIN)
The BOI report also requires basic information about beneficial owners and company applicants:
- Full legal name
- Date of birth
- Residential address
- Copy of non-expired ID (e.g., license or passport)
Who qualifies as a beneficial owner for an LLC?
For LLCs, a beneficial owner is any individual who owns 25% or more of the company, exercises substantial control over the business (e.g., managers), or receives substantial economic benefits from the business assets.
Who qualifies as a beneficial owner for a corporation?
For corporations, beneficial owners include individuals in positions such as CEO, CFO, General Counsel, or anyone with similar authority. This may include any “middle man” who acts as an owner, even if they don’t hold the majority control. Beneficial owners of a corporation also include any shareholder who owns or controls 25% or more of the corporations ownership interest.
What forms of identification are acceptable for the BOI intake form?
FinCEN won’t accept all government issued IDs. The following options are acceptable:
- A non-expired U.S. driver’s license (including any driver’s licenses issued by a commonwealth, territory, or possession of the United States);
- A non-expired identification document issued by a U.S. state or local government, or Indian Tribe;
- A non-expired passport issued by the U.S. government; or
- A non-expired passport issued by a foreign government (only when an individual does not have one of the other three forms of identification listed above).
Do I have to have an EIN or will my SSN work?
If you have an EIN you must use it. If you don’t have an EIN, you can use your SSN in its place.
What if I don’t have a U.S. address for my company?
FinCEN allows you to use our Registered Address on file in your state.
Do I need a FinCEN ID?
No, a FinCEN ID is not required. It’s recommended for clients concerned about privacy or those who have multiple companies and want to save time entering the same information repeatedly.
How do I hire you to file my BOI Report?
You can hire us to file your BOI Report by logging in to your online account. Once logged in, click the “Hire Us” tab, select your company, and follow the steps to have us take care of the rest! We currently charge a $25 filing fee for this service in Montana.