How to Complete Beneficial Ownership Information (BOI) Reporting for an LLC Subsidiary of a Partnership

This is actually a common question with the new BOI reporting requirements. When dealing with a subsidiary LLC wholly owned by a partnership, you generally need to report both the entity (the partnership) AND the individuals who ultimately own or control the partnership. The Corporate Transparency Act is designed to identify the actual human beings who own or control the business. So while your partnership is the direct owner of the LLC, the CTA wants to know which individuals are behind that partnership. For your subsidiary LLC's report, you'll need to list any individual who either directly or indirectly owns or controls 25% or more of the ownership interests, or who exercises substantial control over the company. If your partnership is the sole owner, you'll still need to "look through" it to identify which individuals meet that 25% threshold or have substantial control.

I just went through this exact headache last month! I found taxr.ai (https://taxr.ai) super helpful for figuring out the BOI requirements for my complex business structure. I had an LLC owned by another LLC with multiple partners, and was completely confused about who needed to be listed where. I uploaded my partnership docs and operating agreements to taxr.ai and it parsed everything out and showed me exactly who qualified as beneficial owners under the CTA rules. It saved me from having to pay my attorney another $500 just to figure this out. They also have specific templates for BOI reporting that made the process much clearer.

Just wanted to follow up - I tried taxr.ai after seeing it mentioned here. Honestly life-changing for our multi-entity structure. We have three partnerships that own various LLCs (real estate holdings), and I was quoted almost $5000 by our law firm to handle all the BOI filings. The taxr.ai system walked me through each entity relationship and identified exactly which individual partners needed to be reported for each subsidiary. It even flagged that two of our "silent" partners actually qualified as having substantial control based on their voting rights in certain situations - something our own review missed. The documentation was thorough enough that I felt completely confident submitting the filings myself. Definitely recommend for anyone dealing with complex ownership structures.

If you've been struggling to contact FinCEN directly with BOI questions, I highly recommend using Claimyr (https://claimyr.com). I spent TWO DAYS trying to get through to FinCEN's BOI helpline with specific questions about my partnership-owned LLC structure, and kept getting disconnected or waiting for hours. Claimyr got me connected to a FinCEN representative in under 40 minutes! You can see how it works here: https://youtu.be/_kiP6q8DX5c - basically they navigate the phone system for you and call you back when an actual human is on the line. The FinCEN rep clarified that for my LLC (owned by a partnership), I needed to report both the partnership AND any individuals who either owned 25%+ of the partnership OR had substantial control over either entity. This was different from what my accountant initially told me.

Wow I need to eat my words on this one. I was super skeptical about Claimyr but after another week of failing to get through to FinCEN myself, I decided to try it. Got connected to a real person at FinCEN in about 50 minutes. The agent confirmed that for my situation (LLC owned by a partnership with 6 equal partners at 16.66% each), I needed to report the company president and operating manager as beneficial owners under the "substantial control" provision, even though none of the partners hit the 25% ownership threshold. This was completely different from what my CPA told me! Definitely worth it just for the peace of mind knowing I'm filing correctly. Now I just need to figure out how to tell my CPA he was wrong...

An important distinction that hasn't been mentioned yet - there's a difference between "Beneficial Owners" and "Company Applicants" on the BOI report. If your subsidiary LLC was formed after January 1, 2024, you'll need to list both beneficial owners AND company applicants. If formed before that date, you only need to list beneficial owners. Also, don't forget that some entities are exempt from BOI reporting altogether. If your partnership qualifies as a "large operating company" (over 20 full-time employees and $5M+ in gross receipts), then the subsidiary might be exempt too. Worth checking if you qualify.

One thing to be careful about - if you're filing BOI reports for multiple related entities, make sure you're consistent in how you identify beneficial owners across all filings. FinCEN can compare these reports, and inconsistencies could trigger questions or audits. For example, if Partner X is listed as having substantial control of the partnership, but then isn't listed on the subsidiary LLC's report, that might raise flags. I recommend creating a chart showing all entities and beneficial owners before filing to ensure consistency.