On July 24, 2024, FinCEN updated its Corporate Transparency Act FAQ section to confirm that disregarded entities may use their parent’s Employer Identification Number when filing Beneficial Ownership Reports. “If the disregarded entity does not have an EIN, it is not required to obtain one to meet its BOI reporting requirements so long as it can instead provide another type of TIN[.]” FinCEN Beneficial Ownership Information Frequently Asked Questions F.13.

For further questions regarding the update, please contact Liskow attorneys Leon Rittenberg III and Kevin Naccari, Jr. and visit our Corporate Transparency Act Resource Page.

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