01. International Tax

We provide tailored solutions to complex global businesses doing business in the U.S. Small or multinational, we guide clients through the maze of complex U.S. international tax rules.

02. Offshore Tax Compliance

We assist clients with specialized counsel to fix noncompliance with international tax reporting and penalties. FBAR, forms 8938, 8621, 3520, 926, 5471 and 5472 are among the most common forms that we solve through compliance programs such as streamlined procedures, Voluntary Disclosure Program or the Delinquent International Information Return Submission Procedures (DIIR).

03. Small Business Tax Planning

We assist small and medium businesses with efficient tax structuring to improve efficiencies. Proper tax election, s-corp elections and partnership planning are some of the main solutions offered.

04. Controversy Tax

We guide and represent clients before the IRS including examinations and appeals, as well as represent clients in Tax Court or Federal Courts.

05. Tax Debt Resolution

We help clients to face harsh collection activities, including liens, levies and obtaining a collection alternative such as an offer in compromise, installment payment plans, among others.

06. IRS Criminal Investigations

Our Firm provides representation before IRS Criminal Investigation Division, including Malta Pension Plans and summons.

07. High Net Worth & Family Offices

Assistance with estate planning for select clients and those with cross-border operations, planning for inheritance taxes, and gift taxes in the USA.

08. Start-Ups & Business Tax

No matter how small the idea, we assist clients with the best tax planning and alternatives for their business.

09. Crypto Tax

Our Firm provides tax planning and tax advice on crypto assets and crypto events, including mining, forks, rewards, and disposition/exchange of crypto.

10. BOI Report- Corporate Transparency Act

We assist business owners, CPA and tax preparation firms to file the Beneficial Ownership Information (BOI) report with the FinCEN.

BOI Compliance: Who is the Company Applicant?

BOI Report

08.20.2025

Continuing our BOI REPORT series, today we address an important question: Who qualifies as a company applicant of a reporting company? This topic is particularly relevant for entities created or registered on or after January 1, 2024, as they are required to report company applicant information under the Corporate Transparency Act (CTA).

Defining the Company Applicant

The company applicant refers to individuals directly involved in the creation or registration of a reporting company. As per the regulations, there can be up to two individuals identified as company applicants:

    1. The person directly filing the creation or registration documents.
    2. The person primarily responsible for directing or controlling the filing process, if multiple individuals are involved.

Applicability to Reporting Companies

Only reporting companies created or registered on or after January 1, 2024, are obligated to report their company applicants. Here’s how the requirement applies:

    • Must Report Applicants:
      • Domestic companies created in the United States after January 1, 2024.
      • Foreign companies first registered to do business in the U.S. after January 1, 2024.
    • Exempt from Reporting Applicants:
      • Domestic companies created in the U.S. before January 1, 2024.
      • Foreign companies registered in the U.S. before January 1, 2024.

Are Professionals Like Accountants or Lawyers Considered Applicants?

Yes, in some cases, accountants or lawyers may qualify as company applicants. This determination relies on their role in the filing process:

    • If they directly file the formation or registration documents, they are considered applicants.
    • If they are primarily responsible for overseeing or controlling the filing, they also qualify as applicants.

For example:

    • An attorney overseeing incorporation through a law firm is considered an applicant.
    • A paralegal submitting the documents at the attorney’s direction also qualifies as an applicant.

Can a Company Applicant Be Removed from a BOI Report?

No, once reported, company applicant information cannot be removed, even if the applicant no longer has a relationship with the reporting company. Companies must include applicant details in the initial BOI report but are not required to update this information if changes occur in the applicant’s status.

Relevance for Tax Professionals.

Understanding the definition and reporting obligations of company applicants is vital for ensuring BOI compliance. Tax professionals should be aware that reporting companies formed or registered after January 1, 2024, must properly identify and report their applicants to avoid penalties. Accountants, attorneys, and other professionals involved in the filing process need to understand their potential designation as company applicants based on their role in the creation or registration of the company. This knowledge is crucial to help clients navigate the compliance requirements effectively.