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1/9/2024 9:10:16 PM EDT
[Last Edit: Scollins][Edited]
As a Sole Proprietor, I'm exempt from these requirements.  But not all Sole Proprietors are exempt.  The FAQ states "No, unless a sole proprietorship was created (or, if a foreign sole proprietorship, registered to do business) in the United States by filing a document with a secretary of state or similar office."

My wife (small business CPA) was telling me about the requirements that impact many of her clients, and in her words "it will be a clusterfuck nightmare."  The reporting window just opened on 1/1/2024, and existing companies have until 12/31/2024 to report.  New companies formed in 2024 have to report within 30 90 days.  Fines are apparently $500/day

If your FFL is an LLC, partnership, S-Corp or C-Corp, it is almost 100% likely you need to report to FinCEN based on CTA-2021.


Lots of information here in the FAQ:
https://www.fincen.gov/boi-faqs
1/21/2024 1:47:37 AM EDT
[#1]
Thought companies formed in 2024 had 90 days to report?
Death to quislings.
1/21/2024 8:59:04 AM EDT
[#2]
Quote History
Originally Posted By backbencher:
Thought companies formed in 2024 had 90 days to report?
View Quote

https://www.fincen.gov/boi-faqs#G_1
Yes if the company is formed between Jan 1, 2024 and Dec 31, 2024.  The deadline is 30 days for companies formed on or after Jan 1, 2025.
Heller II - Challenging DC's bans on semi-automatic rifles, large-capacity ammunition feeding devices, and its onerous and expensive handgun registration process. http://www.HellerFoundation.org/
2/9/2024 9:57:16 PM EDT
[#3]
Just had my inspection yesterday and the agent mentioned this and told me to stay sole proprietor.

2/9/2024 10:11:30 PM EDT
[#4]
Quote History
Originally Posted By Chowser:
Just had my inspection yesterday and the agent mentioned this and told me to stay sole proprietor.
View Quote

IOI's are not agents they are auditors.  They are also not attorneys and there are many reasons when an LLC is superior to a sole proprietor.
Heller II - Challenging DC's bans on semi-automatic rifles, large-capacity ammunition feeding devices, and its onerous and expensive handgun registration process. http://www.HellerFoundation.org/
3/6/2024 1:27:51 PM EDT
[#5]
Thanks for the heads up. I had never heard of this and without this post I doubt I would have. I just finished my filling and it only took 5 minutes to get it done.
3/6/2024 2:50:35 PM EDT
[#6]
seems like its only for companies created after jan 1 2024. or im reading it wrong?

Attached File
www.newnanarmscompany.com
3/6/2024 3:11:37 PM EDT
[#7]
Quote History
Originally Posted By IHTFP08:
seems like its only for companies created after jan 1 2024. or im reading it wrong?

View Quote

You are reading it wrong.  It's for all corporations and LLC's that don't meet one of the 23 exemptions.  

Attached File

“The difference between treason and patriotism is only a matter of dates.”

"And how can man die better
Than facing fearful odds,
For the ashes of his fathers,
And the temples of his Gods."
3/6/2024 6:20:48 PM EDT
[#8]
I filed as well - took about 15 mins for all my LLC's.  Last thing I need is for my LLC that holds my NFA items to be revoked, cancelled, etc...
“The difference between treason and patriotism is only a matter of dates.”

"And how can man die better
Than facing fearful odds,
For the ashes of his fathers,
And the temples of his Gods."
3/6/2024 8:22:25 PM EDT
[#9]
Quote History
Originally Posted By IHTFP08:
seems like its only for companies created after jan 1 2024. or im reading it wrong?

https://www.ar15.com/media/mediaFiles/213456/company_PNG-3151104.JPG
View Quote View All Quotes
View All Quotes
Quote History
Originally Posted By IHTFP08:
seems like its only for companies created after jan 1 2024. or im reading it wrong?

https://www.ar15.com/media/mediaFiles/213456/company_PNG-3151104.JPG


A "company applicant" is different than BOI's for a company.


E. 1. Who is a company applicant of a reporting company?

Only reporting companies created or registered on or after January 1, 2024, will need to report their company applicants.

A company that must report its company applicants will have only up to two individuals who could qualify as company applicants:

The individual who directly files the document that creates or registers the company; and
If more than one person is involved in the filing, the individual who is primarily responsible for directing or controlling the filing.


Basically it is saying for companies formed after 1/1/2024, not only do companies have to report their BOIs, they also have to report/designate the individual who is completing the form (i.e. the person responsible for filling it out.)
3/8/2024 5:36:22 PM EDT
[#10]
Tag.

How are we supposed to find out about these things? This is the first I have heard of any of this and apparently this was from 2021?

Thanks for the heads up. Looks like I have research to do.
" Laziness is an essential part of all walks of engineering."
3/18/2024 8:25:55 AM EDT
[#11]
Thanks,

Just did it. Needed a copy of my DL for documentation, EIN, etc. Took maybe 5 mins since I already had scanned copies of that info.
www.newnanarmscompany.com
3/18/2024 8:36:25 AM EDT
[#12]
Just more BS to stifle small business owners...
3/18/2024 11:56:27 PM EDT
[#13]
More news....  Seems the government is losing in court on this issue.  Still somewhat of a hassle, as only "members as of 3/1/2024 of the National Small Business Association" are covered at the moment.



https://www.cohencpa.com/knowledge-center/insights/march-2024/court-decision-suspends-boi-reporting-for-some-not-all
10/16/2024 11:25:37 PM EDT
[#14]
Bump as I just got around to doing it.  It's not as bad as the annual state filing and at least it's free.
Heller II - Challenging DC's bans on semi-automatic rifles, large-capacity ammunition feeding devices, and its onerous and expensive handgun registration process. http://www.HellerFoundation.org/
10/16/2024 11:31:19 PM EDT
[#15]
Quote History
Originally Posted By Bubbles:  Bump as I just got around to doing it.  It's not as bad as the annual state filing and at least it's free.
View Quote


It's not as bad yet and it's free at the moment.  
I sell firearms produced by the finest child labor in the world, be it Filipino, Muslim, Mormon, Arizonan, or Texan.
12/12/2024 5:07:04 PM EDT
[#16]
From FINANCIAL CRIMES ENFORCEMENT NETWORK website:

BOI e-Filing Alert:  Please note that beneficial ownership information reporting requirements have been affected by a recent federal court order. The Department of the Treasury is appealing that order. In the meantime, reporting companies are not currently required to file a BOIR and are not subject to liability if they fail to do so while the applicable order remains in force.  However, reporting companies may still opt to file a BOIR.
FFL 10 / FEL 20 / SOT 02 / PA Certified High-Explosive Blaster
12/25/2024 12:30:24 AM EDT
[#17]
Meanwhile government hides all it’s activities  and prosecutes anyone exposing them.
12/25/2024 2:39:57 AM EDT
[#18]
Quote History
Originally Posted By TreddBarton:
From FINANCIAL CRIMES ENFORCEMENT NETWORK website:

BOI e-Filing Alert:  Please note that beneficial ownership information reporting requirements have been affected by a recent federal court order. The Department of the Treasury is appealing that order. In the meantime, reporting companies are not currently required to file a BOIR and are not subject to liability if they fail to do so while the applicable order remains in force.  However, reporting companies may still opt to file a BOIR.
View Quote


Bad news - the stay on enforcement has been lifted by a higher court.
I sell firearms produced by the finest child labor in the world, be it Filipino, Muslim, Mormon, Arizonan, or Texan.
12/25/2024 10:13:03 PM EDT
[#19]
Do it sooner rather than later if it's not done yet.  While I knocked it out in ten minutes, I can see servers melting down if everyone waits until the last day hoping for the courts to intervene.
Heller II - Challenging DC's bans on semi-automatic rifles, large-capacity ammunition feeding devices, and its onerous and expensive handgun registration process. http://www.HellerFoundation.org/
12/25/2024 10:29:28 PM EDT
[#20]
Quote History
Originally Posted By jtb33:

You are reading it wrong.  It's for all corporations and LLC's that don't meet one of the 23 exemptions.  
View Quote


The easiest way to remember which 23 groups are exempt is that if you already have to report ownership under other laws, you don't have to report again under this law.

Texas Cop Shop suit gave us an injunction, but that was overturned.

https://www.journalofaccountancy.com/news/2024/dec/boi-injunction-lifted-reporting-deadline-is-jan-1-2025.html

The deadline for most reporting companies to file beneficial ownership information (BOI) reports was extended to Jan. 13, 2025, by the Financial Crimes Enforcement Network (FinCEN), hours after a Monday court ruling reinstated the reporting requirement.

The Fifth Circuit Court of Appeals granted a Department of Justice (DOJ) motion to lift an injunction put in place by a district court ruling Dec. 3 that the DOJ appealed.

After the Fifth Circuit order, FinCEN, which enforces the Corporate Transparency Act (CTA), announced that, for reporting companies that had been required to supply BOI information by Jan. 1, their new filing deadline was Jan. 13.

Specifically, the FinCEN alert said that, because Treasury "recognizes that reporting companies may need additional time to comply given the period when the preliminary injunction had been in effect," reporting deadlines were extended as follows:

   Reporting companies created or registered before Jan. 1, 2024, have until Jan. 13, 2025, to file initial BOI reports with FinCEN. (These companies would otherwise have been required to report by Jan. 1, 2025.)
   Reporting companies created or registered in the United States on or after Sept. 4, 2024, that had a filing deadline between Dec. 3, 2024, and Dec. 23, 2024, have until Jan. 13, 2025, to file initial BOI reports with FinCEN.
   Reporting companies created or registered in the United States on or after Dec. 3, 2024, and on or before Dec. 23, 2024, have an additional 21 days from their original filing deadline to file initial BOI reports with FinCEN.
   Reporting companies that qualify for disaster relief may have extended deadlines that fall beyond Jan. 13, 2025. These companies should abide by whichever deadline falls later.
   Reporting companies that are created or registered in the United States on or after Jan. 1, 2025, have 30 days to file initial BOI reports with FinCEN after receiving actual or public notice that their creation or registration is effective.
I think the hardest thing for good LE working for good agencies to really absorb is that there are whole departments full of exactly the complete fuckheads we rail against here. - vectorsc
12/27/2024 6:38:48 PM EDT
[#21]
And the injunction is reinstated.

Feels Like Groundhog Day as Preliminary Injunction of Enforcement of the Corporate Transparency Act Is Back
Just days ago, we reported that on December 23, 2024 the United States Court of Appeals for the Fifth Circuit (the “Fifth Circuit”) ordered that the nationwide preliminary injunction against the enforcement of the Corporate Transparency Act is stayed, and that the compliance deadline was once again in effect, subject to some nominal extensions of the upcoming deadlines. We also reported that the Fifth Circuit ordered the “appeal is EXPEDITED to the next available oral argument panel” and the situation remains fluid and continues to evolve. On December 26, 2024, the Fifth Circuit Court of Appeals vacated its own stay of the preliminary injunction of the enforcement of the January 1, 2025 deadline for reporting compliance. Currently, pleadings are on an expedited schedule and the appeal is calendared for oral argument on March 25, 2025, and the situation continues to remain fluid.

The key takeaway is that at this time the injunction is in effect and reporting companies are not currently required to file their beneficial ownership reports.
View Quote
Plano, Texas...........the Gun Nut Capitol of Gun Culture, USA
https://www.youtube.com/watch?v=pELwCqz2JfE

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