Over the past few weeks, we have received several questions from churches and Christian schools regarding the applicability of reporting Beneficial Ownership Information (BOI) to FinCEN as part of the Corporate Transparency Act (CTA) for churches and nonprofits. Below is a link to a comprehensive article from Batts, Morrison, Wales, and Lee regarding this issue. However, please be aware that several exemptions to the general reporting requirement apply, one of which is tax-exempt entity.
For purposes of this exemption, a tax-exempt entity is defined as:
A. An organization that is described in section 501(c) of the Internal Revenue Code of 1986 (Code)…and is exempt from tax under section 501(a) of the Code, except that in the case of any such organization that ceases to be described in section 501(c) and exempt from tax under section 501(a), such organization shall be considered to continue to be described in this paragraph…for the 180-day period beginning on the date of the loss of such tax-exempt status;
Please read the full text and discuss with an attorney if you are still unsure on your status.