IRS Moratorium on ERC Claim Processing Until 2024
Supreme Court to Decide Whether Unrealized Income Can Be Taxed

FinCEN Released BOI Guidance – Don’t be Confused About Accounting Firm Exemption

The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) recently published the Beneficial Ownership Information (BOI) Small Entity Compliance Guide to assist small businesses with the upcoming reporting rules from the Corporate Transparency Act.


Page 4, Chart 2 – Reporting Company Exemptions of the guide includes #15, “accounting firms.” AICPA indicated in a recent meeting that the information is misleading. Large firms and public accounting firms registered under the Sarbanes Oxley Act will be exempt from the BOI reporting rules. However, generally, all other accounting firms are not exempt and do need to file a BOI report. Take a look at other exemptions, just in case.


AICPA appealed to FinCEN back in 2021 that CPA firms should have a blanket exemption to the requirement because CPA firms licensed or certified by state boards of accountancy already provide ownership information to the states. This effort was unsuccessful.


Unless Congress takes action to delay, entities required to report will do so on or after Jan. 1, 2024.


Most small accounting firms are subject to the Corporate Transparency Act’s BOI reporting rules | Wolters Kluwer

Beneficial ownership information (BOI) reporting | Resources | AICPA & CIMA (

Beneficial Ownership Reporting - TXCPA Federal Tax Policy Blog (

Corporate Transparency Act: Are You Prepared? (



Hallie Lewis

The American Institute of Certified Public Accountants (AICPA) has raised concerns about the clarity of exemptions in the Beneficial Ownership Information (BOI) Small Entity Compliance Guide from the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN). While large and publicly registered accounting firms are exempt, other accounting firms, including smaller ones, must comply with the BOI reporting rules. AICPA previously lobbied for a blanket exemption, arguing that state-licensed CPA firms already share ownership information with state boards of accountancy, but this request was unsuccessful.

Verify your Comment

Previewing your Comment

This is only a preview. Your comment has not yet been posted.

Your comment could not be posted. Error type:
Your comment has been saved. Comments are moderated and will not appear until approved by the author. Post another comment

The letters and numbers you entered did not match the image. Please try again.

As a final step before posting your comment, enter the letters and numbers you see in the image below. This prevents automated programs from posting comments.

Having trouble reading this image? View an alternate.


Post a comment

Comments are moderated, and will not appear until the author has approved them.

Your Information

(Name is required. Email address will not be displayed with the comment.)