Tips & Advice

What is a FinCEN Identifier & How Can I Use It?

Question: What is a FinCEN Identifier? Answer: A “FinCEN identifier” is a unique identifying number that FinCEN will issue to an individual or reporting company upon request after the individual or reporting company provides certain information to FinCEN. An individual or reporting company is not required to obtain a FinCEN identifier. An individual or reporting company may only receive one FinCEN identifier. Your company may include FinCEN identifiers in its BOI report instead of certain required information about beneficial owners or company applicants. FinCEN Identifiers for Individuals Individuals may

Is a Manager of an LLC a Beneficial Owner?

Question: Homer Simpson is a manager of World Wide Widgets, LLC, but he is not a member. Is Homer a beneficial owner of the LLC? Answer: Yes because as a manager he can make important decisions on the LLC’s behalf, thereby exercising substantial control over it. Source: Small Business Compliance Guide pages 26

Can a Trustee be a Beneficial Owner?

Question: Can a trustee of a trust that owns an interest in a company be a beneficial owner? Answer: Yes. A trustee of a trust or similar arrangement may exercise substantial control over a reporting company. The following individuals may hold ownership interests in a reporting company through a trust or similar arrangement: A trustee or other individual with the authority to dispose of trust assets. A beneficiary who is the sole permissible recipient of trust income and principal or who has the right to demand a distribution of or

Who is a Beneficial Owner?

Does a Subsidiary of a Report Exempt Entity Have to File a FinCEN Report?

Does an Entity that Assists a Tax-Exempt Entity Have to File a FinCEN Report?

Does a Tax-Exempt Entity Have to File a FinCEN Report?

Does an Inactive Entity Have to File a FinCEN Report?

Does a 20+ Employee Company Have to File a FinCEN Report?

FinCEN’s Estimate of Time & Cost to File a FinCEN Report

Question: How much time will I have to spend if I do a “do-it-yourself” FinCEN report? Answer: The following text is from a Notice by the U.S. Treasury Department on 09/29/2023. FinCEN estimates that 32,556,929 entities will submit initial beneficial owner information reports (“BOIRs”) in Year 1 (2024). In Year 2 (2025) and beyond, FinCEN estimates that the number of initial BOIRs filed will be 4,998,468 per year. FinCEN estimates the average burden of reporting BOI as 90 minutes per response for reporting companies with simple beneficial ownership structures (40 minutes to read

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