what's new for 2024

This isn't new for 2024, but this is certainly a requirement. US persons are required to file with the US Treasury a return commonly known as an FBAR (or Report of Foreign Bank and Financial Accounts - FinCEN Form 114), listing all non-US bank and financial accounts. These are required if on any day of any calendar year a US person (e.g. US citizen, green card holder, corporation, charity or trust) has ownership of or signature authority over non-US bank and financial accounts where all accounts have an aggregate (total) balance greater than the equivalent of $10,000.

FBARs are separate to and in addition to United States income tax return. An FBAR for 2023 is technically due to be filed by Monday 15 April 2024. The filing date for an FBAR for 2023 is, however, automatically extended to Tuesday 15 October 2024.

BOI (Beneficial Ownership Information) Report refers to identifying information about the individuals who directly or indirectly own or control a company. 

 If your company existed before January 1, 2024, it must file its initial beneficial ownership information report by January 1, 2025.

If your company was created or registered on or after January 1, 2024, and before January 1, 2025, then it must file its initial beneficial ownership information report within 90 calendar days after receiving actual or public notice that its creation or registration is effective. Specifically, this 90-calendar day deadline runs from the time the company receives actual notice that its creation or registration is effective, or after a secretary of state or similar office first provides public notice of its creation or registration, whichever is earlier.

If your company was created or registered on or after January 1, 2025, it must file its initial beneficial ownership information report within 30 calendar days after receiving actual or public notice that its creation or registration is effective.

Failure to file will result in a penalty of $500 per day, up to $10,000.