FinCen BOI Filing Requirement? – It’s Anyone’s Guess

Last week, the Department of the Treasury further clarified that not only will fines not be imposed but enforcement actions will also be paused.  It’s anyone’s guess what the point of this filing is now.  An update related to foreign controlled entities and their reporting requirements will be forthcoming. 

This rule was going to be a tough one to impose and enforce from inception given the sheer magnitude of small businesses that have been and continue to be filed in each State.  It sounds like some logic and reason is being applied.