Corporate Transparency Act: How to File Beneficial Ownership Information Report (BOIR)

January 1 2024 and the corporate transparency Act is now in effect finsen has opened the reporting portal for you to report your beneficial ownership information how do you do that hi I'm John Strow with stromm law today we're going to be going through how do you actually report your beneficial ownership information to fcen if you have a reporting company I've already done this I walked through the process with one of my companies already today I'm here to show you basically this is a pretty easy process it worked for me it's good to see that this is something we've been building up to for a while I wasn't sure if it was actually going to work I'm happy to report so far so good I will say this is not something to wait on who knows if the system will be able to handle the number of people who are going to kick the can down the road till December November October go ahead and get this in a thing to think about the IRS usually turns off the Ein automatic application process for the the last few days of the year this is probably not a situation you want to put yourself in either for yourself or for your clients once you know you're going to be reporting this information go ahead and get it in also what I'm not going to be doing is going through the process to get a finin ID number that is in a separate video if you want to watch that go get that so let's take a look over at the finsen website so here we are on their web page if you come down here to beneficial owner ship information we're going to click on that as I mentioned before you can get a finsen identifier this is a process that goes through your login.gov ID so if you already have that it'll be easy to jump in update your information like I said we've got a separate video on that now here's where we go we're going to file a report with the beneficial ownership information eiling system and this is probably based on the existing architecture for fbar reporting what you see here is here's where they've got the BSA Bank secrecy act filing information you could start that here but the other things you can either click on this button to file your beneficial ownership information report or you can click on this button to get started both of them take you to the same place when you go to that same place what does it look like well beneficial ownership information report what are we doing you've got three options to fill these out and we're going to go through two of them the first filling out the PDF I've already downloaded the PDF we'll get to that one it's going to ask for the same information as if you filled out an online beneficial ownership information report now we'll click this in just a second the third option if you have access to some third-party systemto system API or a application programming interface this is where somebody else has built an interface that plugs into finson computers you can use their dashboard their tool to upload your information I don't have that but I do know that a number of the um registered agent companies are offering this as a service so that you can use their service to upload your information there you can manage it internally there that that's probably going to be a good option for companies that actually have a number of beneficial owners but we're going to focus on these other two options that are available we're going to start with the online beneficial ownership information so we're going to click prepare and submit the good news about this you know we walked straight to it you've got these five tabs you know filing information reporting company company applicants for companies that are formed or register to do business in the US on or after January 1st 2024 then the beneficial owners and then finally submitting everything the good news about this look you can jump back and forth as you can see I've I've already jumped in and we're right into filling out the information so initial report is what a lot of us are going to be doing if you have a prior report or updating a prior report either correcting or updating you'll type in the entity's legal name their tax number identification type so whether it's an actual Ein a social security number or a foreign tax ID finally if it's a foreign number you're going to put in the foreign jurisdiction where it's formed then they're autofilling in the date it was created now since most of us are going to be doing initial reports we're going to go with that and that's it for page one going on to the next page if you want this entity to get its own finin ID this is going to be where you request that so it may show up later that you want entities to to have their exist their own finsen IDs to facilitate other reporting this is how you would do that now what are we doing next again this follows along with a lot of what we saw in the proposed regulations going through things I didn't really see anything in this form either the PDF or the online version that changed my mind or that looked really different from the regulations and that's good this is what we want it should be hopefully pretty easy to get this done so first you're going to put in the company's legal name after that if it has has any trade names or dbas you'll put that in if you need to add more again you're just clicking the button to add more remove remove and there you go now form of identification now this is where you're getting into a little bit more information about the company so tax identification type uh this is the tax ID number that they're going to use to correlate across systems so if it's a social security number because it's an entity that relies on the owner social you'll do that again most entities have have their own tax ID number and that's where You' use that next jurisdiction of formation so this would be initially the country and then once you do that so it's a domestic rep reporting company then you'll figure out what state Louisiana and if you need to change it if you get something wrong you can just come in Arizona there you go it's that easy then the current address remember for the current business address that's where it goes it's not the the attorney's address it's not the accountant's address it's not a PO Box um it really is the address number Street number they're not giving you the option for a PO Box here and then once you're done with that going on to the next what you should also see I'm going through and putting in information but mostly not filling out anything you know you can if you're I I wouldn't recommend actually filling it out this way because you might miss something but the fact is is I'm going through and just putting in the you know just skipping past most of it so here we are question 16 if this is an existing reporting company you're going to take this box and by ticking that box you know we're going to get this pop up it means we're not going to fill out company applicant information now existing companies are ones formed on or before December 31 2023 so here we are January 1 2024 just about every entity that is an existing entity has been formed there's a slight chance you may get something in later in the mail but really the time has passed we have figured out all of those prior existing entities so we're we know which ones those are when you tick that box and it's going to blank out so we cannot report who the company uh applicants are remember these are going to be two people somebody who actually files the documents with fin with the state office or tribe to form the entity and somebody who directs it now there's more information to that basically advisers or people who are helping to create the entity this is where we'll have their information because I form entities uh with clients I have a f my finsen identifier number uh I would potentially put this here for any new entities and what they've got is when you've got a finsen ID you put it here and then it'll put in the it'll stop you from putting in anything else so that's all that would go in basically here's your name that you use to provide to that reporting company and then the finsen ID that's all they have to put in is the finsen ID so once you've put that in or here you know with this an existing reporting company because we don't have to put any company applicant information down that's it we're done on this page we're going to go to page four of this beneficial ownership information so this is where for all of the beneficial owners you're going to fill in what is effectively lines 35 through 51 and this is lining up with how I remember the proposed regs but what are you putting in well you know there's an option here if there is a minor owner of an interest you'll take this box recognizing there's a minor owner we're we are reporting the adult who is parent next line 36 if you have a finsen ID you would type this in here and that is a 12-digit number again I just put one with a bunch of zeros what you see once I put that number in everything else is done they're going to coordinate on the back end if you say Vincent identifier you know 1,000 quad zero quad Zer is one of your beneficial owners great you're done and then you can go on to the next page now I'm going to come back but that's it if you had that finen ID you're basically done when you when I clear out that information now again what you see is here this is all the other information that we need that pops back up but once we've got the finsen identifier it goes away but clearing it out well next if you've got an exempt entity so perhaps this is a newly exempt entity or it's an entity that you just formed and you're claiming it as exempt take that box and then because it's exempt then you're just going to put in the uh entity's legal name and you're done with that then for beneficial owners what are we doing last name first name middle name suffix date of D birth again stuff that you're supposed to be reporting on this their residential address again residential not attorney's address CPA not a PO Box again this is this is where they're going to ask you to Port all of that finally identifying document type and the document number the options driver's license uh state or local issued ID passport or foreign passport what is not an option using your social security number to identify yourself and the ID they're looking for The Unique number is something that's used to identify you and is issued by a state or local entity it's not your social security number I know I'd seen some people who' say said oh well you're going to have to upload your social again you're not uploading your social if you don't want to uh then where did this document come from what jurisdiction so United States District of Columbia and then this is where you will upload an uh an electronic copy of that document so you can use PDFs pngs jpegs uh there was not anything I saw on how to you know the minimum uh file size on this or minimum resolution they basically took what I used now I scanned when I was creating my finen ID I scanned my driver's license with my high-end scanner so I'm not really worried about it it it's a good look copy but I don't know if they're going to kick anything back again I wouldn't get too cute on that I would rather use something else you know use a good quality scan of your of your ID so that you're not potentially getting issues later finally submitting the information uh what are you going to get uh completing the fields email confirm your email first name and last name who is submitting this and then you'll I'm not reporting anything so I'm not going to click submit Boi but what you should see here is look you're going to get this once you're done with it it does kick out a a confirmation page page it'll have a confirmation um of what you for filed and a way to download a report of that so once you get this all done and you're you're going to hit submit using this form what you'll end up with is a uh a confirmation of what you filed so here we're looking at my status confirmation you know I had the beneficial owner ID of the report I've redacted that the submission tracking ID act redacted that email that I submitted as well also redacted what you also see is that we're going to be able to download this at the bottom I can't get that to pull up it's just going to be difficult but what you should see is that once you're done you get a report that you've got your proof that this was done there's trans tracking ID this is something that's just going to make all of us feel better that hey look it was done I've got a report of this and you can get a copy of exactly what was filed now I mentioned there's also a pdf version of this I have not use this just yet but let's walk through and what you're going to see is that this PDF looks a lot like what we saw in the uh online version again completing it hyper reporting initial you know if you take the box for initial report then what you're uh it's not going to it's graying out all of this information but if you untake that box well correct a prior report then you've got to put in this information so people know or so finsen knows what you're updating but we're going to again just use initial report and this is a four-page PDF that's following along with the same information we had before now what do we have if you want a f in ID you can take that box reporting company legal name you're going to put in like I did test name LLC if there are trade names you can add those in identification number type again Ein Social Security or foreign where was it Formed what's the current address going on to page three if it's an existing reporting company and it'll it'll gray out all the information on the company applicant but even if you did have a finsen IDs one so it's finsen ID is a 12-digit number three groups of four digits and oh look I got the right numbers and so it grade everything out once I put that finin ident ID number in there when I take it out and it comes back out and so it's it it knows what you're doing it's taking that finsen ID and updating the PDF so you don't have to put that in then here at the end Fen ID number can put that in for anybody again it's the same information that we saw in the initial report in the online form now if we come back and what we're gonna if we were to file the PDF well then what are we doing we're going to like I said here we are on the website prepare the uh boir just download that it it'll get you that PDF then submit it well it's the same confirmation page where it's your name and uploading this and then you drag and drop it here for your PDF and that way you know if you're using the PDF form of this then you're done the reason I think you know until I find a an API system that I like probably going to use the PDFs for most of my companies just because it seems like it'll be easier to track you can say here on January 1st these were our beneficial owners company applicants if we need to come back to it we're not going to have to reenter all that information we've got it there and we can just start from that point what we'll do you know for simple entities we may just use the online form because well look you know for my company I've got one one owner made it easy for me to get that done I also added my wife because we live in a community property State and I think that triggers her to be a beneficial owner as well so that you know that was easy I knew what our information was I was able to get it uploaded but if you're in a situation with there there were going to be a lot of beneficial owners it's probably going to be easier to use the pdf version of that if you're using an outsourced API that will be easier if you have a lot and you're just managing lots of entities so good news today it was good to see that this worked as planned and it took me about 10 minutes to get through this outside of me taking notes and just kind of fiddling around with the system to see how things work I don't see this as being a big issue at least for now I would not wait to get these in again we were worried about the system working period it seems to have worked uh the thing beyond that was were so many people going to get in and melt down the servers that's still a possibility I haven't seen anything that says it won't happen but this is a great time go ahead and get these reports in so that you're done you're not waiting for or finsen or potentially dealing with some sort of power outage with them or server outage thanks so much we'll see you on the next video

Channel: Strohmeyer Law PLLC

Views: 18,699

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Id: VWgCiT_zjGE

Length: 19min 7sec (1147 seconds)

Published: Mon Jan 01 2024