The new BOIR requirement comes from the Corporate Transparency Act (CTA) passed by Congress in 2021. It became effective on January 1, 2024. The intent behind the beneficial ownership information report to the U.S. Department of the Treasury is to increase companies' visibility.

The deadline for filing a BOI report depends on when a company was created or registered. Companies created before January 1, 2024, have until January 1, 2025, and companies created or registered after January 1, 2024, and before January 1, 2025, have 90 days from their date of creation or registration.

This includes corporations, limited liability companies (LLCs), limited liability partnerships, business trusts, and many limited partnerships. An entity that is required to file a BOIR is a “reporting company.” Both domestic and foreign entities may be reporting companies, with slightly different criteria for each.

1) Securities reporting issuer 2)Governmental authority 3) Banks 4) Credit union 5) Depository institution holding company 6) Money services business

7) Broker or dealer in securities 8) Securities exchange or clearing agency 9) Other Exchange Act registered entity 10) Investment company or investment adviser 11) Venture capital fund adviser 12) Insurance company 13) State-licensed insurance producer 14) Commodity Exchange Act registered entity 15) Accounting firm 16) Public utility 17) Financial market utility 18) Pooled investment vehicle 19) Tax-exempt entity 20) Entity assisting a tax-exempt entity 21) Large operating company 22) Subsidiary of certain exempt entities 23) Inactive entity