In a letter addressed to members of the House Financial Services Committee and Senate Banking Committee, the AICPA and all 54 state CPA societies, including WSCPA, asked that H.R. 4035 and S. 2623, the Protecting Small Business Information Act of 2023, or similar legislation to delay, be included in any year-end legislative package. The bills would delay the Beneficial Ownership Information (BOI) reporting requirement until all three rules under the Corporate Transparency Act have been finalized to specify that all such rules would take effect on the same date.
Currently, BOI reporting requirements are expected to go into effect January 1, 2024. The letter cited unclear and vague definitions in the rule and the need for additional input, including access to the filing form or platform for the requirements, which has not yet been released by Financial Crimes Enforcement Network (FinCEN).
The letter, sent on December 11, 2023, follows a similar letter sent in October which specifically recommended that FinCEN extend the deadline from the proposed 90 days to one year and expand the applicability of the deadline to include not only new entities created in 2024 but ALL entities created thereafter, as well as entities making updates or corrections to their original filings.