Updated Jan. 15, 2025 – The Fifth Circuit Court of Appeals panel reinstated the nationwide injunction against the Corporate Transparency Act on December 26, which means that impacted small businesses aren’t required to comply with the law’s reporting until further proceedings take place in March 2025. Read the latest ADA News story.
Updated Dec. 27, 2024 – In light of a recent federal court order, reporting companies are not currently required to file beneficial ownership information with FinCEN and are not subject to liability if they fail to do so while the order remains in force. However, reporting companies may continue to voluntarily submit beneficial ownership information reports. fincen.gov.boi Read the latest ADA News story.
Updated Dec. 26, 2024 – Because of a federal Court of Appeals decision, reporting companies are once again required to file beneficial ownership information with FinCEN and the Department of Treasury has extended the reporting deadline. See more information here.
Updated Dec. 17, 2024 – You may have seen in the news and in reporting by the ADA that last week a Texas court issued a nationwide preliminary injunction that blocks enforcement of the Corporate Transparency Act (CTA).
What This Means for You
As a result of this nationwide federal injunction, entities required to file a beneficial ownership interest (BOI) report are NOT CURRENTLY required to do so this year.
- If you have already filed, you don’t need to worry about doing anything further.
- If you have NOT filed, you can wait to take action when final judgment in the case is made or further developments arise.
From October 30, 2024 – The Beneficial Ownership Information (BOI) report is a federal requirement that was put into place earlier this year, pursuant to the Corporate Transparency Act. The purpose of this requirement is to combat the use of businesses as money-laundering operations.
The ADA has sent emails about this new reporting requirement, and also prepared a helpful information memo — ADA Corporate Transparency Act Information for Dental Practices.
You may also reference this guide from the federal government — FINCEN Small Entity Compliance Guide
Your dental practice must file a Beneficial Ownership Information (BOI) Report if it meets either of the following criteria:
• The practice employs fewer than 20 people; or
• The practice generates less than $5 million (gross receipts) in revenue annually
Filing can be done online and free of charge at https://www.fincen.gov/boi. Dentists who have already filed have reported the process to be straightforward and not too time-consuming. There is also an instructional video to watch if needed.
Existing dental practices must file a Beneficial Ownership Information (BOI) Report by January 1, 2025 (if you haven’t already done so).
For new dental practices formed in 2024, file your BOI report within 90 days of forming your new practice. (Dental practices created on or after January 1, 2025, will be required to file within 30 days of forming your new practice.)
Beneficial ownership information reporting is not an annual requirement. A report only needs to be submitted once, unless the filer needs to update or correct information. However, if there is any change in the information reported about the reporting company or its beneficial owners, the reporting company must file an updated report within 30 calendar days after the date on which the change occurs.
We encourage you to contact the ADA (see information memo linked above for contacts) with any questions about this new federal requirement.
