Must a Company Report Its BOI to FinCEN if It Ceased to Exist Before Jan. 1, 2024?

No, a company is not required to report its beneficial ownership information to FinCEN if it completely ceased to exist as a legal entity before January 1, 2024. This means the company must have fully and irrevocably dissolved according to the relevant state or tribal laws. Typical steps include filing dissolution paperwork, receiving confirmation of dissolution, paying all related taxes or fees, ceasing business operations, and winding up affairs such as liquidating assets and closing bank accounts.

However, if a Reporting Company continued to exist in any capacity on or after January 1, 2024, it must report its beneficial ownership information to FinCEN, even if it had stopped conducting business before that date. Similarly, any company created or registered on or after January 1, 2024, must report its beneficial ownership information if it ceased to exist before the due date of its Initial BOIR.

The exact point at which a company ceases to exist as a legal entity depends on the laws of the jurisdiction where it was created or registered. Note that administrative dissolution or suspension for reasons such as non-payment of fees does not equate to ceasing to exist unless it becomes permanent.