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Corporate Transparency Act / BOI Reporting Intake
Collects the beneficial-ownership and company-applicant information needed to determine reporting status and prepare a FinCEN BOI report, with current exemption screening.
What is a Corporate Transparency Act / BOI Reporting Intake?
A Corporate Transparency Act / BOI Reporting Intake is a legal document that collects the beneficial-ownership and company-applicant information needed to determine reporting status and prepare a FinCEN BOI report, with current exemption screening.
Companies working out what the Corporate Transparency Act requires of them. The CTA's scope has shifted through litigation and rulemaking, so this intake captures the facts and flags exemptions, and a Hart David Carson attorney can then settle the filing question and prepare the FinCEN report if one is required.
Corporate Transparency Act / BOI Reporting Intake template, current for 2026
Written for a CTA regime that is still unsettled. It screens for entity type (domestic vs. foreign) and for the 23 exemption categories, including the large-operating-company and subsidiary exemptions, and it captures company-applicant data for entities formed after the reporting rule took effect. Because the enforcement scope for domestic entities has been in flux, the document leaves the final determination to attorney review and states no fixed rule of its own.
How HDAi does this differently
Unlike a static form, HDAi runs a guided interview and assembles your Corporate Transparency Act / BOI Reporting Intake as you answer. When you want it finished, a licensed Hart David Carson attorney reviews it and tailors it to your facts before you sign. The interview and the first draft are automated. The judgment belongs to an attorney.
What you’ll be asked
A short interview in plain language that asks only what this document needs.
- What is the date of this intake? Dates the intake and anchors the exemption and reporting-status screening to a point in time, since CTA rules and deadlines are time-sensitive.
- Which attorney or firm professional is preparing this intake? Identifies the professional coordinating the analysis so the client knows who to contact and the file is properly attributed.
- Identify the reporting company (the entity being screened). The CTA reporting obligation attaches to the entity. We need its exact legal name and organizational details to test it against the 'reporting company' definition and to populate any FinCEN filing.
- What type of entity is the company? Entity type bears on CTA coverage (generally entities created by a state or tribal filing) and on which exemptions may be available.
- Is the company domestic or foreign for CTA purposes? This is now the question everything else turns on. Under the March 2025 FinCEN interim final rule, domestic reporting companies are exempt and only foreign reporting companies (as to their non-U.S.-person owners) remain in scope. A domestic reporting company is created by filing with a U.S. state/tribal office; a foreign reporting company is a non-U.S. entity registered to do business in the U.S.
- Confirm the reporting posture under the current (March 2025 interim final) FinCEN rule that applies to this company. This question gates the rest of the analysis. Under FinCEN's interim final rule published March 26, 2025, domestic reporting companies and U.S.-person beneficial owners are exempt from BOI reporting; only foreign reporting companies remain in scope, and they report only their non-U.S.-person owners. The final determination is still routed to counsel, but this captures the applicable regime up front.
- In what jurisdiction was the company formed or first registered? Confirms the filing that triggers CTA coverage and, for foreign entities, the U.S. registration that creates the obligation.
- On what date was the company created or (if foreign) first registered to do business in the U.S.? The creation or registration date drives the filing deadline tier (30 days for entities created on or after Jan. 1, 2025, 90 days for 2024 entities, and the pre-2024 FinCEN schedule for older ones) and whether company-applicant reporting applies.
- What is the company's EIN or other taxpayer identification number? FinCEN requires a TIN (EIN, SSN/ITIN, or foreign identifier) for the reporting company. Screening for a missing TIN also flags a filing readiness gap.
- What is the company's principal place of business (U.S. street address)? FinCEN requires the reporting company's principal U.S. address (no P.O. boxes or third-party agent addresses); we confirm it is complete and usable for the filing.
- Has the company ever been dissolved, terminated, merged out of existence, or administratively cancelled? Prior dissolution or termination bears on the existence of any reporting obligation at all. An entity that ceased to exist before the rule took effect may not be a reporting company, while a reinstated entity may be. We flag it now for counsel.
- Describe the prior dissolution, termination, merger, or reinstatement (dates and circumstances). Records the timeline so counsel can check which reporting dates the entity existed on and whether any filing obligation attaches.
- Do any of the following exemption categories appear to apply to the company? Select all that may apply. The CTA exempts 23 categories of entities. Flag any potential exemption and we know which way to go, either filing a BOI report or documenting the exemption instead. These options cover a broad set of the 23 enumerated categories.
- Explain the basis for any exemption selected above (or note why none applies). Documents the factual support for an exemption so counsel can confirm it and the file records the reasoning if no BOI report is filed.
- Identify each beneficial owner (any individual who owns/controls 25% or more, or who exercises substantial control). FinCEN requires reporting each beneficial owner: individuals with 25%+ ownership OR substantial control (senior officers, appointment/removal authority, important-decision authority). For a foreign reporting company, only non-U.S.-person owners are reportable under the current rule.
- On what basis does each identified beneficial owner qualify? Select all that apply. Captures whether individuals qualify by ownership, by substantial control, or both: the two independent tests FinCEN applies. This shapes who must be listed and why.
- For each beneficial owner, provide date of birth, residential address, and acceptable ID document (type, number, issuing jurisdiction). FinCEN requires each beneficial owner's DOB, residential street address, and a unique identifying number from an acceptable document (passport, driver's license, or state ID), plus an image of that document.
- Is any reportable owner a foreign person who lacks a U.S. passport, U.S. driver's license, or U.S. state ID? When no acceptable U.S. identification document exists, FinCEN permits (and requires) a foreign passport. This is especially relevant for foreign reporting companies, whose non-U.S.-person owners often have only foreign documents.
- For each foreign owner without U.S. identification, provide the foreign passport details (issuing country, number) and confirm a document image is available. FinCEN accepts a foreign passport only when the individual has no U.S. document. Capture the issuing country and unique number, and confirm you can supply an image of the passport.
- Do any beneficial owners or applicants have a FinCEN Identifier they wish to use? If so, list them. A FinCEN Identifier can be reported in lieu of an individual's personal information, simplifying the filing and future updates. We note any that already exist.
- Is company-applicant information required (i.e., was the company created or first registered on or after January 1, 2024)? Only entities created/registered on or after Jan. 1, 2024 must report company applicants (up to two). Pre-2024 entities are exempt from this requirement, so we ask up front.
- Identify the company applicant(s): the individual who directly filed the formation/registration document and, if different, the individual primarily responsible for directing the filing. For post-2024 entities FinCEN requires up to two company applicants: the direct filer and the person who directed the filing. We collect their identities.
- For each company applicant, provide date of birth, business or residential address as applicable, and acceptable ID document details. Company applicants require the same identifying data as beneficial owners; applicants acting in a business capacity may use their business address rather than a residential one.
- Describe the company's ownership and control structure, including any parent entities, holding companies, or trusts above it. A structure map lets counsel trace beneficial ownership through intermediary entities and confirm no reportable individual has been missed.
- Are any ownership interests held through a trust? Trust-held interests require looking through to trustees, certain beneficiaries, and grantors with revocation power to identify the reportable individuals.
- Is any beneficial owner a minor child? A minor child's interest may be reported through a parent/guardian, whose information is reported instead until the child reaches majority: a special rule we flag now.
- Does any exempt entity sit in the ownership chain above the company? When an exempt entity is an intermediate owner, individuals whose only interest runs through that exempt entity generally need not be reported: this can materially shorten the owner list.
- What is the applicable filing deadline for the initial BOI report (if known)? Deadlines vary by creation date. Entities created on or after Jan. 1, 2025 have 30 days, 2024 entities have 90 days, and pre-2024 entities follow the FinCEN schedule then in effect. The document states this tiered logic in Section 7(b), and recording the date drives the engagement timeline.
- Has any BOI report already been filed for this company? Tells us whether we are preparing an initial report, or an updated/corrected report, which has its own 30-day trigger when reported information changes.
- What is the firm engaged to do here? Select all that apply. Defines the scope of the firm's role so responsibilities (analysis, preparation, filing, and ongoing update monitoring) are clear.
- To whom and where should notices to the company be sent (name, address, and email)? Populates the Notices provision so formal communications reach the right person. If left blank, the document defaults to the company's principal place of business.
- To whom and where at the firm should notices be sent (name, address, and email)? Populates the firm side of the Notices provision. If left blank, the document defaults to the address in the engagement letter.
- Who is the individual authorized to certify, on the company's behalf, that the information provided is true, correct, and complete? FinCEN filings must be certified as accurate. We identify the authorized person who will stand behind the data and sign this intake.
- Any additional facts, pending changes, or concerns relevant to the reporting analysis? Anticipated changes create update-report obligations; surfacing them now lets counsel plan the 30-day update filings and avoid penalties.
- Which state's law governs this engagement and intake? Sets the governing law for the engagement terms and any dispute over this intake, independent of the federal CTA analysis.
Frequently asked
About the Corporate Transparency Act / BOI Reporting Intake and how HDAi works.
What is a Corporate Transparency Act / BOI Reporting Intake? +
A Corporate Transparency Act / BOI Reporting Intake is a legal document that collects the beneficial-ownership and company-applicant information needed to determine reporting status and prepare a FinCEN BOI report, with current exemption screening. It is for companies working out what the Corporate Transparency Act requires of them. The CTA's scope has shifted through litigation and rulemaking, so the intake captures the facts and flags exemptions, and a Hart David Carson attorney can then settle the filing question and prepare the FinCEN report if one is required.
Is HDAi's Corporate Transparency Act / BOI Reporting Intake legally binding? +
The Corporate Transparency Act / BOI Reporting Intake is a working document rather than a contract. It organizes the facts and decisions the next step needs (an attorney's work, a filing, or a board decision) and does not become binding by signature. Treat the output as preparation, and have a licensed Hart David Carson attorney finish whatever follows from it.
Do I need a lawyer to use this Corporate Transparency Act / BOI Reporting Intake? +
You can generate and download the Corporate Transparency Act / BOI Reporting Intake in minutes, free of charge. A licensed Hart David Carson attorney can then review it and tailor it to your facts before you sign, which is the part no template can do.
What makes this Corporate Transparency Act / BOI Reporting Intake current for 2026? +
Written for a CTA regime that is still unsettled. It screens for entity type (domestic vs. foreign) and for the 23 exemption categories, including the large-operating-company and subsidiary exemptions, and it captures company-applicant data for entities formed after the reporting rule took effect. Because the enforcement scope for domestic entities has been in flux, the document leaves the final determination to attorney review and states no fixed rule of its own.
How long does the Corporate Transparency Act / BOI Reporting Intake take? +
Estimated time about 18 min (35 questions), depending on how much you already know. The document assembles as you answer. Export it as PDF or Word, or send it to a Hart David Carson attorney for review.
Does this Corporate Transparency Act / BOI Reporting Intake work in my state? +
HDAi's interview is state-aware. If you ask an attorney to finish the draft, a licensed Hart David Carson attorney confirms it against your state's requirements before you rely on it. Validity and required formalities vary by state.
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