fincen 现在还需要报吗？(Beneficial Ownership Information美国公司不用再报。不影响FBAR)
FinCEN BOI申报恢复但外国公司仍需申报，FBAR不受影响。
1. 关键信息
- #1 @braket 指出 Beneficial ownership information reporting 要求恢复，新截止日期 2025-03-21；外国公司仍需申报（#1）。
- #5 @时空空 澄清 FINCEN 114/FBAR 一直需报，BOI 是近期新增且现已不再要求（#5）。
- #10 @braket 询问 non resident alien 及身份变更（NR/RA）是否需报 #fincen；#11 @时空空 回答 NR 不报（#10-11）。
- #14 @PigHasDream 指出 RA 即使 F1 满五年理论上仍需申报（#14）。
2. 羊毛/优惠信息
无
3. 最新动态
- #1 @braket 引用 FinCEN 2025-03-26 临时最终规则，定义变更与豁免生效（#1）。
4. 争议或不同意见
- #8 @braket 询问总账户资产是否可减去贷款；#9 @时空空 主张应计入（#8-9）。
5. 行动建议
- 外国公司需在 2025-04-25 前或注册后 30 天内提交 BOI 报告；个人继续履行 FBAR/FINCEN 114 义务。
FinCEN.gov
FinCEN.gov
Beneficial ownership information reporting requirements are now back in effect, with a new deadline of March 21, 2025, for most companies. Prior to March 21, 2025, FinCEN will assess its options for further modifying deadlines. For more information,...
**On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) announced that, consistent with the Department of the Treasury’s March 2, 2025, announcement it was issuing an interim final rule that removes the requirement for U.S. companies and U.S. persons to report beneficial ownership information (BOI) to FinCEN under the Corporate Transparency Act. FinCEN published this interim final rule on March 26, 2025.
In the interim final rule, FinCEN revises the regulatory definition of “reporting company” to mean only those entities that are formed under the law of a foreign country and that have registered to do business in any U.S. State or Tribal jurisdiction by the filing of a document with a secretary of state or similar office (formerly known as “foreign reporting companies”). FinCEN also exempts entities previously known as “domestic reporting companies” from BOI reporting requirements. Thus, through this interim final rule, all entities created in the United States — including those previously known as “domestic reporting companies” — and their beneficial owners will be exempt from the requirement to report BOI to FinCEN.
However, foreign entities that meet the new definition of a “reporting company” and do not qualify for an exemption from the reporting requirements must report their BOI to FinCEN under new deadlines. These foreign entities will not be required to report any U.S. persons as beneficial owners, and U.S. persons will not be required to report BOI with respect to any such entity for which they are a beneficial owner.
The following deadlines apply for foreign entities that are reporting companies:
Reporting companies registered to do business in the United States before March 26, 2025, must file BOI reports by April 25, 2025.
Reporting companies registered to do business in the United States on or after March 26, 2025, have 30 calendar days to file an initial BOI report after receiving notice that their registration is effective.
In accord with its prior notices and the Department of the Treasury’s March 2, 2025, announcement, FinCEN is applying all exemptions and deadline extensions in the interim final rule as of March 21, 2025, and will further not enforce any beneficial ownership reporting penalties or fines against U.S. citizens or domestic reporting companies or their beneficial owners.
**
BOI和海外账户不是同一个东西吧？
给fincen报的不就是海外账户的BOI吗？我是法盲，还请指教
我看这个boi好像是注册公司的信息吧
FINCEN 114一直都有一直都要报的
BOI这是个最近几年新加的，不用报了
fincen总账户资产是资金减去debt吗？
啥叫总账户资产。。
FINCEN 114是按账户报的吧
“FinCEN Form 114, the Report of Foreign Bank and Financial Accounts (FBAR), is an annual, mandatory report filed with the U.S. Department of the Treasury to disclose foreign accounts with an aggregate value exceeding 10,000 at any time during the calendar year.”
aggregate 这里，我理解是总的银行账户里的存款。抱歉，总资产的确用词不当。应当是总的存款。但这里是否可以减去银行的贷款呢？比如我从中行接1万美元的消费贷转到中行的储蓄卡里。这算达到1万美元存款吗？
我觉得是算的，而且这是一个报了肯定没毛病，没报容易出大事的选择题，自然是选择报
non resident aline需要报吗？如果我报1040NR，需要报fincen吗？我的情况有些尴尬，身份变过好几次，从NR->RA->NR->RA.
NR不报
那国内的养老金账户和公积金账户呢？
要报的 这又不是你的accountant客服渠道。。再多了问AI吧
Fincen是不是理论上RA就要报？哪怕是F1满五年的RA