B.O.I. Report

The Beneficial Ownership Information Report

How does a reporting company report a corporate trustee as a beneficial owner?
For purposes of this question, “corporate trustee” means a legal entity rather than
an individual exercising the powers of a trustee in a trust arrangement.
If a reporting company’s ownership interests are owned or controlled through
a trust arrangement with a corporate trustee, the reporting company should
determine whether any of the corporate trustee’s individual beneficial owners
indirectly own or control at least 25 percent of the ownership interests of the
reporting company through their ownership interests in the corporate trustee.

• For example, if an individual owns 60 percent of the corporate trustee of a
  trust, and that trust holds 50 percent of a reporting company’s ownership
  interests, then the individual owns or controls 30 percent (60 percent × 50
  percent = 30 percent) of the reporting company’s ownership interests and is
  therefore a beneficial owner of the reporting company.
• By contrast, if the same trust only holds 30 percent of the reporting
  company’s ownership interests, the same individual corporate trustee owner
  only owns or controls 18 percent (60 percent × 30 percent = 18 percent) of
  the reporting company, and thus is not a beneficial owner of the reporting
  company by virtue of ownership or control of ownership interests.
  The reporting company may, but is not required to, report the name of the corporate
  trustee in lieu of information about an individual beneficial owner only if all of the
  following three conditions are met:
• the corporate trustee is an entity that is exempt from the reporting
  requirements;
• the individual beneficial owner owns or controls at least 25 percent of
  ownership interests in the reporting company only by virtue of ownership
  interests in the corporate trustee; and
• the individual beneficial owner does not exercise substantial control over the
  reporting company.

Corporate Entities:
Statutory Trust
Business Trust
Foundation
Not created by the filing of a document with the secretary of state or similar office

What is it?
Which law governs these requests? The Corporate Transparency Act
Who qualifies for exemptions?
How do you file? File a report using the BOI E-filing system.
How do I get a FinCEN ID? Create a FinCen id (optional)