BOI Reporting Update for Dental Practices: Where Things Stand Now

If you’ve been following the rollercoaster of changes to Beneficial Ownership Information (BOI) reporting requirements under the Corporate Transparency Act (CTA), you’re likely aware of the ongoing legal battles. Here’s a summary of the current status and what dental practice owners need to know as of early January 2025.

Key Developments in BOI Reporting Requirements

Since early December 2024, BOI enforcement has been caught in a legal tug-of-war, with multiple court rulings and appeals creating uncertainty. Below is a timeline of notable events:

  • December 3, 2024: A Texas court issued a preliminary injunction, halting BOI enforcement and raising constitutional concerns about the CTA.
  • December 5, 2024: The government appealed the injunction, seeking to reinstate the BOI requirements.
  • December 23, 2024: The Fifth Circuit Court briefly lifted the injunction, reinstating the BOI filing deadline. FinCEN responded by extending the due date to January 13, 2025.
  • December 26, 2024: The appeals court reimposed the injunction, once again halting enforcement. Oral arguments are set for March 25, 2025.
  • January 4, 2025: The U.S. Department of Justice filed a motion with the Supreme Court, requesting it to lift the injunction and allow BOI reporting enforcement to resume. The decision now rests with the Supreme Court, adding yet another layer of uncertainty.

What This Means for Dental Practices

  1. No Current Obligation to File: Enforcement remains on hold for now, so dental practices are not required to submit BOI reports.
  2. Optional Filing: FinCEN’s system remains open for voluntary reporting, though no penalties will apply if you choose to wait until enforcement officially resumes.
  3. Be Prepared: With the DOJ’s appeal now in the Supreme Court’s hands, enforcement could resume at any time. If the injunction is lifted, businesses may be given a short window to comply.

If you have already filed, you are in good shape and shouldn’t need to do anything else regardless of how the courts eventually rule.  

Next Steps for Dental Practice Owners

Given the frequent changes and legal uncertainty, dental practice owners should stay informed and ready to act quickly. While there’s no immediate need to file, preparing your BOI information in advance will save time if enforcement resumes abruptly. 

We understand the frustration caused by these back-and-forth rulings. Our team is here to provide clarity and guidance, ensuring you’re ready to comply whenever the situation stabilizes. If you have any questions about BOI reporting or would like help gathering your beneficial ownership information, don’t hesitate to reach out.

Stay tuned for more updates, and we’ll keep you informed of any further developments in this ever-evolving situation.

What Dentists Need to Know About New BOI Reporting Requirements

The new Beneficial Ownership Information (BOI) filing requirements are now in effect, and the deadlines are fast approaching. Don’t risk compliance headaches or costly penalties – including a $591 daily fine and possible criminal charges – let us handle this for you.

For most dental practices, BOI filing isn’t complicated but ensuring accuracy and protecting your sensitive business information is essential. Don’t outsource filing to a shady third-party vendor, as many are turning out to be. If you’d like to tackle it yourself, FinCEN’s website offers a straightforward filing option. 

Filing Deadlines for Existing Entities:

  • BOI report due by December 31, 2024
  • Contact us by December 2, 2024, for assistance

For those looking to take this off their plate entirely, our team at Edwards & Associates has the expertise to manage it seamlessly and securely. We’ll guide you through every step, making sure your filing is complete, compliant, and worry-free.

Contact us today and let us handle this so you can focus on what you do best — caring for your patients.

BOI Reporting FAQ

The process for BOI filing can be straightforward for small dental practices. Here are six critical questions to guide you through whether and how to file:

1. Does My Practice Need to File?

Most dental practices will need to file, especially if structured as corporations, LLCs, or partnerships registered with a state. There are 23 types of exempt companies, but most small, privately owned dental practices do not qualify for these exemptions.

2. Who Qualifies as a Beneficial Owner?

A ‘beneficial owner’ includes individuals who:

  • Exercise substantial control over the business, or
  • Own or control at least 25% of the company’s equity interests.

For dental practices, this typically means the practice owners themselves. Exceptions exist, including minor children, employees without ownership stakes, and certain creditors.

3. Who Is Considered a Company Applicant?

A company applicant is anyone who files the registration paperwork for your entity or directs that filing. In most cases, this will include the practice owner, or anyone designated to handle legal filings.

4. What Information Will I Need to Gather?

When preparing your BOI report, you’ll need the following details:

  • For the Company: Legal name, DBA names, primary U.S. business address, jurisdiction of formation, and tax identification number.
  • For Each Beneficial Owner and Applicant: Full legal name, birthdate, residential or business address, and a valid ID number (e.g., passport or driver’s license).

5. What Is a FinCEN Identifier, and Should You Consider It?

A FinCEN Identifier is an optional unique number that you or your company can request, simplifying the reporting process by allowing you to file your BOI without disclosing sensitive personal details like a Social Security Number. If privacy is a concern, this may be worth considering.

6. How Do I File My BOI Report?

The BOI report can be filed electronically here on FinCEN’s website. Before starting, make sure you have all necessary information ready to avoid delays or errors.