Lisa and the Law

FinCEN releases guidance on Beneficial Owners of Homeowner Associations

Posted on April 19, 2024

If a Homeowner’s Association (HOA) does not meet the definition of a tax-exempt entity under the CTA (exempt from taxation pursuant to a provision of 501(c) of the Internal Revenue Code) it must file a Beneficial Ownership Information Report (BOIR) and disclose its Beneficial Owners. FinCEN released guidance yesterday in the form of FAQ D.13 as to who is considered a Beneficial Owner of an HOA). Many HOAs are exempt from taxation under Internal Revenue Code 528 which is not an exemption under the CTA. Be sure to check your HOAs tax exemption with the IRS to determine whether it needs to file a BOIR.

Related Services: CTA Compliance

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