Editor's note: This post has been updated to reflect the following: On Dec. 3, 2024, the U.S. District Court for the Eastern District of Texas issued a preliminary nationwide injunction against the CTA reporting requirement. The U.S. Department of Justice filed an appeal. On Feb. 18, 2025, the Court granted FinCEN a stay order on the preliminary injunction. As a result, BOI reporting requirements are now mandatory. The deadline for most reporting companies is March 21, 2025.
Sole or partial physician practice owners need to report basic information about themselves to a division of the U.S. Department of Treasury to comply with the Corporate Transparency Act (CTA).
The CTA, passed in 2021, is intended “to make it harder for bad actors to hide or benefit from ill-gotten gains through shell companies or opaque ownership structures.”1 The law requires certain domestic and foreign LLCs, corporations, and other entities to file information about individuals who directly or indirectly own or control companies registered to do business in the United States. Business owners, including physician practice owners, must report beneficial ownership information (BOI) to the Financial Crimes Enforcement Network (FinCEN) at https://boiefiling.fincen.gov/ or via select third-party providers. Most companies must report their information by March 21, 2025. Going forward, companies must file within 30 days of creation or registration. Companies also must file an updated BOI report within 30 days of a change in the information originally reported about the company or its beneficial owners.
FinCEN requires the following information about each of the company’s beneficial owners:
This information will be available to federal, state, local, and tribal officials for law enforcement purposes. Health care companies, including physician practices, are not among the 23 specific types of entities exempt from these reporting requirements. (The Small Entity Compliance Guide provides more information about what type of companies are exempt.)
— Angela M. Lanigan, MPA, RD, LD, AAFP Career & Practice Strategist
1. Financial Crimes Enforcement Network. Beneficial Ownership Information. Updated April 18, 2024. Accessed May 21, 2024. https://fincen.gov/boi-faqs#C_2
Posted on May 31, 2024 by FPM Editors
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