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.

It’s Back! BOI Filing Update on New Deadlines and Compliance

If you’ve been tracking the new Beneficial Ownership Information (BOI) reporting requirements under the Corporate Transparency Act (CTA), there have been important updates you need to know. After a brief pause due to a court ruling, the requirements are now back in effect with slightly adjusted deadlines. Here’s what this means for your dental practice.

What Happened?

The CTA mandates businesses, including dental practices, to file BOI reports with the Financial Crimes Enforcement Network (FinCEN). These reports are designed to enhance financial transparency and combat criminal activities such as money laundering.

On December 3, 2024, a federal court issued a preliminary injunction halting the enforcement of BOI filing requirements. However, on December 23, 2024, the Fifth Circuit Court of Appeals lifted the injunction, reinstating the obligation. To account for this delay, FinCEN extended filing deadlines, but not by much.

New Deadlines for Filing

  • Dental Practices Formed Before Jan. 1, 2024: File BOI reports by Jan. 13, 2025.
  • Dental Practices Formed Between Sept. 4 and Dec. 23, 2024: File by Jan. 13, 2025, or 21 days after your original deadline, whichever is later.
  • Dental Practices Formed After Jan. 1, 2025: File BOI reports within 30 days of formation or registration.
  • Disaster Relief Extensions: Practices affected by qualifying disasters may have extended deadlines.

What Your Practice Should Do

  1. Identify Beneficial Owners: These include individuals who own or control at least 25% of your practice or have significant decision-making authority.
  2. Gather Required Information: Compile details such as legal names, addresses, birthdates, and government-issued ID numbers for beneficial owners and company applicants.
  3. File Accurately: Use FinCEN’s e-filing portal to submit your report before the applicable deadline or reach out to us immediately if you want us to handle this for you.
  4. Stay Updated: Ongoing legal proceedings could impact the requirements or timelines, and we will do our best to keep you informed if any further changes occur.

Why Compliance Is Critical

Noncompliance can lead to severe penalties, including fines of up to $500 per day (capped at $10,000) and possible imprisonment for up to two years. Additionally, inaccurate filings can expose your practice to audits and legal scrutiny.

How We Can Help

Filing isn’t especially challenging if your business ownership structure is straightforward. However, if you want help, our team can:

  • Determine if your practice is required to file.
  • Tell you information is needed to file.
  • Ensure your BOI report is filed accurately and on time.

Take Action Now

January 13 will be here before you know it, so gather your information for filing as soon as you can. If you want our help, reach out right away.