FinCEN BOI Reporting Requirement Ends for U.S. Companies

If you own an LLC or other small business, including an LLC that's part of your estate plan, I have some welcome news.

The federal government has eliminated the FinCEN Beneficial Ownership Information (BOI) reporting requirement for U.S. companies and U.S. persons under the Corporate Transparency Act.

That means that millions of business owners who were previously told they needed to submit information about their companies and beneficial owners to the Financial Crimes Enforcement Network, or FinCEN, no longer have that obligation.

For many of our clients, this removes a compliance requirement that had become both confusing and concerning.

What Were the FinCEN BOI Reporting Requirement?

The Corporate Transparency Act was created as part of an effort to combat money laundering and other financial crimes by making it more difficult to hide the identities of people who own or control certain companies.

Beginning in 2024, many corporations, LLCs and other entities were required to report identifying information about their beneficial owners to FinCEN.

For small business owners, that meant determining whether their company was subject to the law, identifying the appropriate beneficial owners, and providing required personal information.

The rules also mattered outside the traditional small-business setting. That's because LLCs can be useful in estate planning.

We’ve reported on this issue before. This article from 2024 talks about the initial reporting requirement, while this article from 2025 talks about the confusion created by competing rulings.

Why This Mattered for Estate Planning

When you hear "LLC," you may immediately think of someone operating a business. But LLCs can also be used as part of a family's broader estate planning strategy.

For example, an LLC may hold family-owned real estate or other assets. Families may use business entities as part of plans designed to manage property, transfer wealth, or provide a structure for shared family assets.

That's why I was paying attention to the BOI requirements.

Estate planning is already an area where details matter. Adding a federal reporting requirement created another issue that families and their advisors needed to consider when an LLC was involved.

It also meant that someone who didn't think of themselves as a "business owner" could potentially have found themselves dealing with a business-related federal reporting rule simply because of the way certain assets were structured.

What Has Changed?

FinCEN changed its regulations so that companies created in the United States are no longer considered reporting companies under the Corporate Transparency Act. As a result, domestic entities — including U.S.-created LLCs — and their beneficial owners are exempt from BOI reporting requirements. U.S. persons are also exempt from having to provide BOI for foreign reporting companies in which they are beneficial owners. The remaining reporting requirements generally apply to certain entities formed under the laws of a foreign country that have registered to do business in the United States.

For the vast majority of individuals and families we work with, the important takeaway is much simpler:

If you have a U.S.-created LLC, you generally no longer have to file a BOI report with FinCEN.

What If You Already Filed?

Many people complied with the original requirements and submitted their BOI before the rules changed.

If that's you, you may be wondering whether you need to update that report when your information changes.

Under the current rules, domestic companies are exempt from the BOI reporting requirements, including the requirement to update or correct information they previously reported.

So, you shouldn't assume that an old BOI filing creates an ongoing reporting obligation.

One Less Thing to Worry About… But Keep Reviewing Your Plan

I view this as a positive development for many families. Estate plans can involve trusts, property ownership, beneficiary designations, business entities, and other moving pieces. Removing an unnecessary reporting obligation simplifies one small part of that picture.

But a change in BOI reporting requirements doesn't mean you can put an LLC or estate plan on autopilot.

If an LLC is part of your estate plan, it's still important to make sure the ownership structure, operating agreement, and your estate planning documents continue to work together as intended. In Georgia, you are also still required to file an annual registration for your LLC with the Secretary of State.

Laws change. Families change. Assets change. Your plan should change when necessary, too.

At Kimbrough Law, we help families understand not only which estate planning tools may be appropriate, but how those pieces fit together over time. If you have questions about an LLC in your estate plan or whether changes in the law affect your planning, we're here to help. Call Kimbrough Law at 706.850.6910 to schedule a consultation.