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Congress passed the Corporate Transparency Act on a bipartisan basis. This law creates a new beneficial ownership information (“BOI”) reporting requirement as part of the U.S. government’s efforts to make it harder for bad actors to hide or benefit from their ill-gotten gains through shell companies.  A business which qualifies as a “Reporting Company” needs to file the BOI Application this year if the entity(ies) were filed before 2024 and anytime there is a change of beneficial owners or addresses. 

If an entity is a Reporting Company and was or is filed after January 1, 2024, but before January 1, 2025, then it will need to file the BOI Application within 90 days after the entity is formed. If the entity is formed AFTER January 1, 2025, then the BOI Application must be filed within 30 days of creation of the entity. There are 23 types of businesses exempt from reporting. The definitions of a Reporting Company and those exemptions are in the Small Business Guide which can be found at FinCEN’s BOI webpage also provides a Small Entity Compliance Guide; answers to Frequently Asked Questions; and an introductory video. 

There is a good probability that most medical practices who do business through a corporation or limited liability company will need to file a BOI Application. However, some entities may meet the exemption for a large operating company if all six of the criteria required apply to the entity. Thus, all medical practices should review the Small Business Guide and comply if an exception is not met.

If a practice has more than one entity, a BOI Application would likely need to be done for all entities, i.e., if there is an entity for the practice and one to own a building, then file for both.  The willful failure to timely report complete or updated ownership information to FinCEN or provide false or fraudulent information may result in civil or criminal penalties, including civil penalties of $500 per day that the violation continues or criminal penalties including imprisonment up to 2 years and/or a fine of up to $10,000.

In order to be prepared to file the BOI Application, the following information should be gathered for each entity: Full legal name; Tradename or DBA (if any); Employer Identification Number; Business address; Owners’ (members’ or shareholders’) names, dates of birth, residential addresses, and the same information for the Applicant of the Reporting Company (including a copy of the Applicant’s driver’s license). There are several other types of Proof of Identity if any of the individuals do not have a driver’s license. The Applicant information is not necessary if the Reporting Company was formed before January 1, 2024.


Read the Small Business Guide. It has easy-to-read definitions, instructions, and a good chart to ascertain if an entity needs to report. To find the Small Business Guide, go to and click on the blue block on the left side that reflects Small Business Resources and choose Small Business Guide and review it. After you review the Guide, gather the information, and download the drivers’ licenses needed, completing the Application should only take about 30 minutes. Do not stop and close a partial application without filing or info may be lost and then will need to be re-entered.

Next, file on-line by choosing "File BOI E-filing" on the top right of the Small Business Resources page. When completing the Application, leave the dash that is in your EIN out of the form.

When moving forward to the next page, at the bottom right corner, hit the blue “NEXT”. To go back pages, hit the blue “PREVIOUS” button. Do not try to use the arrow keys or information may be lost. 

Download the drivers’ licenses to be dragged into the Application when asked to do so.

When the application is submitted, if advised that there were incomplete section(s), just hit "PREVIOUS" to see the sections with a red square around them and complete them.

When the Application is complete, a confirmation will appear. Download it for the Reporting Company’s File. 

Alert: FinCEN has been notified of recent fraudulent attempts to solicit information from individuals and entities who may be subject to reporting requirements under the Corporate Transparency Act. The fraudulent correspondence may be titled "Important Compliance Notice" and asks the recipient to click on a URL or to scan a QR code. Those e-mails or letters are fraudulent. FinCEN does not send unsolicited requests. Please do not respond to these fraudulent messages, click on any links, or scan any QR codes within them.

Contact Attorney Linda Minck if you require assistance with the new reporting requirements.

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