IRS BOI (Beneficial Ownership Information) Requirement

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A IRS BOI (Beneficial Ownership Information) Requirement is a IRS regulatory requirement that requires IRS-deemed entities to disclose the identities of their beneficial owners.

  • Context:
    • It can (typically) apply to entities like corporations, LLCs, and limited partnerships, requiring them to disclose beneficial ownership details for compliance purposes.
    • It can (often) assist in identifying individuals who may attempt to evade taxes or engage in money laundering and other financial crimes by hiding behind corporate structures.
    • ...
    • It can vary in reporting requirements, with ownership thresholds such as 25% or more, depending on the specific regulations set by the IRS and other regulatory bodies.
    • It can require periodic updates to ensure that any changes in ownership or control are accurately reflected in the records maintained by the IRS.
    • It can be cross-referenced with other data sources, such as FATCA (Foreign Account Tax Compliance Act) filings, to improve transparency and enforcement against financial crimes.
    • It can impose significant penalties for non-compliance, ranging from fines to restrictions on business activities, reinforcing the importance of compliance in high-risk sectors.
    • ...
  • Example(s):
    • 2001: USA PATRIOT Act introduces initial beneficial ownership reporting requirements for financial institutions
    • 2010: FATCA expands reporting requirements for foreign financial assets
    • 2016: FinCEN Customer Due Diligence Rule requires financial institutions to identify and verify beneficial owners
    • 2021: Corporate Transparency Act establishes current BOI reporting framework
    • 2024: Mandatory BOI reporting begins for new and existing entities
    • ...
  • Counter-Example(s):
    • IRS Form W-9, which collects taxpayer identification information but does not provide information on beneficial ownership.
    • IRS Tax Return (1040), which reports individual income but does not capture ownership or control of other entities.
  • See: FATCA (Foreign Account Tax Compliance Act), Anti-Money Laundering (AML), KYC (Know Your Customer), Beneficial Ownership.


References

2024

  • https://www.irs.gov/individuals/international-taxpayers/beneficial-owners
    1. Withholding agents must withhold 30% from payments to foreign payees unless valid documentation establishes the payee's status as a U.S. person or an entitled foreign beneficial owner.
    2. Required documentation should confirm that intermediaries and beneficial owners comply with FATCA regulations.
    3. Documentation must be obtained before payment, and it is invalid if known to be incorrect or unreliable.
    4. If reliable documentation is unavailable, agents must apply presumption rules for withholding.
    5. Payments to joint owners require documentation from each owner to verify withholding exemptions.
    6. Form W-9 identifies a U.S. person payee and includes a Taxpayer Identification Number (TIN); it exempts payees from NRA withholding but may require Form 1099 reporting.
    7. Foreign beneficial owners should provide Form W-8 to confirm their status; various W-8 forms exist based on specific circumstances.
    8. Forms W-8 BEN, BEN-E, ECI, EXP, and IMY are used for different types of foreign beneficial owners to certify withholding eligibility.
    9. Other forms, such as Form W-4 or Form 8233, may be necessary for exemptions on personal services compensation for nonresident aliens.
    10. FinCEN requires corporations, LLCs, and certain entities to report beneficial ownership information beginning January 1, 2024, as part of BOI reporting requirements.
    11. FinCEN’s BOI resources include FAQs, filing infographics, and informational videos; contact FinCEN for BOI inquiries, not the IRS.