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Farm Corporations and LLC’s and the new Beneficial Ownership Reporting

You might have been aware of a looming reporting deadline of January 1, 2025, for the Corporate Transparency Act, which required companies doing business in the United States report their beneficial ownership information to the U.S. Department of Treasury bureau called the Financial Crimes Enforcement Network (FinCEN).


On December 3, 2024, the U. S. District Court for the Eastern District of Texas granted a nationwide preliminary injunction so that reporting requirements for businesses has been suspended on a nationwide basis.


Even though reporting is not required at this time, farm businesses who have filed a form with the secretary of state or similar office in their state to create a business and all foreign companies doing business in any U.S. state or tribal jurisdiction were to be included in this act.


This would have affected agricultural producers because many farms have created companies and use business entities such as limited liability companies (LLC) or a corporation to own assets or operate in today's agriculture.


The Corporate Transparency Act was passed by Congress to make it harder for bad actors to hide from or benefit from their income or gains through shell companies or other non-transparent ownership structures. Civil penalties would have gone into effect for any person who would have willfully violated the BOI reporting requirements of the Corporate Transparency Act.


In the case Texas Top Cop Shop, Inc. v. Garland, a group of six plaintiffs filed a lawsuit in May 2024 claiming that Congress exceeded its authority under the Constitution in passing the Corporate Transparency Act. The Court’s order is a preliminary injunction only and not a final decision.


The Court’s order temporarily pauses enforcement of the Corporate Transparency Act on a nationwide basis, however FinCEN is still accepting beneficial ownership interest filings.To file the beneficial ownership information report electronically, go to the Financial Crimes Enforcement Network (FinCEN) webpage, found here: https://fincen.gov/boi.


Author: Susanne Hinrichs, Extension educator, Agricultural Business Management Team, susanneh@umn.edu




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