In Part 2 of their BOI series, Roger and Annie tackle the most challenging aspects of beneficial ownership reporting requirements, focusing on determining who qualifies as a beneficial owner and the significant penalties for non-compliance. They dissect FinCEN's FAQs about substantial control while highlighting concerning gray areas that could put both business owners and tax professionals at risk. The discussion provides critical guidance for practitioners considering whether to offer BOI services, emphasizing protection strategies like engagement letters and insurance coverage given the potential $591 daily penalties and criminal consequences.

• (00:00) - Welcome to Federal Tax Updates
• (01:41) - Overview of Beneficial Ownership
• (02:43) - FAQs and Compliance Guide
• (06:34) - Reporting Requirements and Deadlines
• (14:26) - Defining Beneficial Owners
• (17:01) - Indicators of Substantial Control
• (29:18) - Accountants and Lawyers as Beneficial Owners
• (32:40) - Clarifying Beneficial Ownership
• (33:51) - Community Property and Beneficial Ownership
• (35:02) - FinCEN's Approach to Reporting
• (37:13) - Penalties and Enforcement
• (42:11) - Practical Implications for Accountants
• (52:59) - FinCEN Identifiers Explained
• (55:47) - Final Thoughts and Recommendations

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