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TXCPA Committee Calls on FinCEN to Delay BOI Filing Deadline for All Entities by One Year

The TXCPA Federal Tax Policy Committee, chaired by David Colmenero, J.D., LL.M., CPA-Dallas, responded yesterday to the FinCEN Notice of Proposed Rulemaking regarding the Beneficial Ownership Information (BOI) reporting that is scheduled to begin Jan. 1, 2024. FinCEN’s proposal temporarily extends from 30 days to 90 days the filing deadline for certain reporting companies to file initial BOI reports.

TXCPA’s Federal Tax Policy Committee suggests that the filing deadline for all existing entities be delayed one year until 2025, the 90-day deadline for new entities be made permanent and the period for reporting subsequent events be extended to at least 90 days, as well.

The BOI reporting, which is currently scheduled to begin Jan. 1, 2024, will require an estimated 32 million existing small businesses to disclose their beneficial owners to FinCEN, with five to six million new business entities required to disclose annually going forward.

Read comments letter here.


Patty Wyatt, TXCPA

Denise, thank you for your inquiry to the TXCPA Federal Tax Policy Blog.

FinCEN received a significant number of comments and feedback in response to its recent Notice of Proposed Rulemaking. The agency may not be able to provide a formal substantive response to every submission.

We will continue to monitor the progress of the proposed rule as well as any additional BOI guidance.

Denise Villarreal

When will FinCEN be expected to respond back to the TXCPA Federal Tax Policy Committee's urgent suggestions?

Patty Wyatt, TXCPA

Anne, thank you for your comment to the TXCPA Federal Tax Policy Blog. We understand your concerns.

However, the Beneficial Ownership Information reporting requirement is mandated by law in the Corporate Transparency Act of 2020. To combat money laundering and other illicit financial activities, FinCEN is to create a beneficial ownership registry that will be accessible to law enforcement and financial institutions. FinCEN has limited flexibility in rolling out this program.

Anne Makins

Instead of a delay in the filing deadline they should be asking that the entire program be revamped. This will affect small businesses, mom and pops, interior designers, contractors, medical practices and on and on, negatively for absolutely no gain to anyone except the professionals that will be handling the filing. I can understand businesses with financial dealings but the rest is ridiculous.

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