BOI reporting requirements :

• Final Rule Sept 30 , 2022 : federalregister . gov / documents / 2022 / 09 / 30 / 2022-21020 / beneficial-ownership-information-reporting-requirements

• Fact Sheet : fincen . gov / beneficial-ownership-information-reporting-rule-fact-sheet

• Proposed regs ( Dec . 15 , 2022 ) on BOI access and safeguards : federalregister . gov / documents / 2022 / 12 / 16 / 2022-27031 / beneficial-ownership-information-access-andsafeguards-and-use-of-fincen-identifiers-for-entities

• Fact Sheet : fincen . gov / nprm-fact-sheet AICPA Tax Odyssey Podcast : https :// taxodyssey . libsyn . com / tso / the-5-ws-ofbeneficial-ownership-information-boi-reporting compliance with customer due diligence requirements under applicable law , with the consent of the reporting company .

• Financial institution ’ s regulator : BOI that has been provided to a regulated financial institution for the purpose of performing regulatory oversight that is specific to that financial institution . The BOI reporting required under the

CTA presents practitioners , particularly non-attorney practitioners , with complex issues to consider . We suggest practitioners pay attention to guidance issued by CalCPA , the AICPA and their insurance carriers in the coming months .

Who Can See the Data ? This is a non-public database , but FinCEN can disclose the information to :

• Federal agencies : When acting in furtherance of national security , intelligence or law enforcement activity .

• State , local and tribal law enforcement agencies : After receiving authorization from a court of competent jurisdiction as part of a criminal or civil investigation .

• Foreign government : Foreign law enforcement agencies , prosecutors and judges in specified circumstances through a request to a federal agency .

• Financial institutions : To facilitate

James C . Counts II , CPA CTFA is owner of James C . Counts II , CPA CTFA and a member of the CalCPA Committee on Taxation . Andrew Mattson is a tax partner with Moss Adams , vice chair of the CalCPA Committee on Taxation and chair of the AICPA Tax Division ’ s BOI Task Force . You can reach them at james @ countscpa . com and Andy . Mattson @ mossadams . com , respectively .

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