BOI Filing for Dental Practice Owners: Our Attempt to Make Messy Timeline More Clear

If you’ve been trying to keep up with the Beneficial Ownership Information (BOI) reporting requirement, you’re not alone in feeling like it’s turned into a legal ping-pong match. Created to crack down on financial crimes, this new rule has become confusing, controversial, and as of now, unenforceable.

Here’s what dental practice owners need to know and what to do (or not do) next.

BOI Requirements: The Timeline That Just Won’t Quit

The Corporate Transparency Act (CTA) was passed in 2021, and it included new reporting requirements for small businesses, including most dental practices. But since then? It’s been chaos. Here’s a blow-by-blow:

  • January 1, 2024 – BOI reporting officially takes effect. New companies must file within 90 days of formation, and existing companies had to file by January 1, 2025.
  • December 3, 2024 – A Texas court issues a preliminary injunction, halting BOI enforcement nationwide and raising constitutional concerns.
  • December 5, 2024 – The federal government appeals the injunction, attempting to reinstate the rule.
  • December 23, 2024 – The Fifth Circuit Court briefly lifts the injunction, reinstating the January 1 deadline. FinCEN (the Treasury’s enforcement arm) responds by extending the filing deadline to January 13, 2025.
  • December 26, 2024 – The appeals court changes its mind again and reimposes the injunction, stopping enforcement once more. Oral arguments are scheduled for March 25, 2025.
  • January 4, 2025 – The Department of Justice files an emergency motion with the U.S. Supreme Court, asking it to lift the injunction and allow enforcement to resume. We now await the Court’s decision.
  • March 1, 2025 – A separate federal court rules the Corporate Transparency Act unconstitutional in National Small Business United v. Yellen. FinCEN announces it will not enforce BOI reporting against the plaintiffs in that case but keeps requirements in place for everyone else.
  • March 25, 2025 – IRS issues a memorandum clarifying that, due to legal uncertainty, BOI enforcement is paused pending further resolution. 

So, What Does This Mean for Dental Practice Owners?

The short version: You don’t have to file right now.

If you’ve already filed? No harm done, just sit tight.

If you haven’t? That’s fine too. The rule still exists on paper, but it’s tangled in legal challenges and is not being enforced at the moment.

But Will I Have to File Later?

Possibly. The Supreme Court could lift the injunction, or Congress could revise the law. But for now:

  • There are no penalties for not filing.
  • FinCEN cannot enforce the rule due to the ongoing legal battles.
  • Filing is on pause, not eliminated.

What Should You Do Right Now?

  • Don’t panic. No action is required at the moment.
  • Stay informed. This could change with little notice, and we will do our best to keep you informed.
  • Keep records ready. If enforcement resumes, filings may need to happen quickly.

Final Thought

We wish this were clearer, but welcome to regulatory whiplash. BOI reporting is either something you don’t have to do – or something you’ll need to do soon, once the courts make up their minds.

We’re watching this closely, and as soon as there’s a final answer, you’ll be the first to know.

Have questions about your practice structure or potential filing obligations? Reach out. We’re here to help you stay out of trouble and focused on your patients, not paperwork.

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.