March 6, 2025
UPDATE: As of February 19, 2025, the Financial Crimes Enforcement Network (FinCEN) announced that the beneficial ownership reporting requirements are now back in place, with a new deadline of March 21, 2026.
FinCEN is currently assessing its options to further extend the deadline. Additionally, there is current legislation in Congress that, if passed, could extend the filing deadline to January 1, 2026. Despite this ongoing review and pending legislation, FinCEN is implementing the CTA as mandated by Congress. This means that, for now, reporting companies are required to file BOI reports.
What is the BOIR?
The Beneficial Ownership Information Report (BOIR) requirement was established by the 2020 Corporate Transparency Act, with reporting requirements by March 21, 2025. The purpose of the BOIR is to combat financial crimes like money laundering, terrorism financing, and human trafficking by identifying the individuals who own and control companies.
Who Needs to File?
If your dental practice has fewer than 20 full-time employees and generates less than $5 million in annual revenue, you must submit the BOIR. If you have any other LLCs or partnerships, such as a real estate LLC or a real estate LLC for your office building, you must also file a BOIR for those entities.
Who is Exempt?
Practices with over 20 employees and more than $5 million in annual revenue are exempt from BOIR filing, as their ownership is already under federal oversight.
Defining 'Beneficial Ownership'
A "Beneficial Owner" is anyone who owns or controls at least 25% of a company. For dental practices structured as partnerships or S-corporations, this includes all partners or stakeholders with a 25% or greater interest.
What Information is Required?
To complete the BOIR, you will need:
- The exact legal name of your practice.
- Your Tax ID Number.
- Your name, birth date, and valid photo ID (passport or driver's license).
This information is required for all beneficial owners, so ensure you gather it for any partners or family members with at least a 25% ownership stake. Remember, if you own property through an LLC, a separate BOIR will also be necessary for that entity.
How to File the BOIR
The BOIR can be filed online at https://boiefiling.fincen.gov/fileboir. The process takes about 10 minutes and is straightforward. You may also opt to print and mail the form but be sure to obtain a tracking number to confirm receipt. Please note that there are many companies with similar domains and website that look official, who will offer to file for you for a fee, this is not necessary at all, so please confirm that you are on a “.gov” website when you file, not a “.com” or “.org.”
When completing the form, indicate this is your "Initial Report" and follow the prompts. You should request a FinCEN ID, which will simplify future updates to your report.
The BOIR is a one-time filing unless there are changes to your entity's ownership. If changes occur, such as a change in beneficial owners, address, or other key information, you must file an updated BOIR within 30 days of the change to remain in compliance.
New Deadline to File
- The new deadline to file is March 21, 2025.
Failure to file the BOIR could result in significant penalties, including a $500 daily fine, potential imprisonment, and fines of up to $10,000. Compliance is not just a legal obligation; it is a safeguard for your practice.
Navigating BOIR compliance can seem daunting, but we are here to help. If you have questions or need further guidance, please reach out. Compliance is more straightforward than it sounds, and we are here to ensure you have everything you need to stay on track.
Not sure where to start? Contact us today!
References
https://fincen.gov/boi