With all eyes on FinCEN's Real Estate Report (RER) rule taking effect December 1, 2025, it's easy to miss the overlap with BOI reporting under the Corporate Transparency Act.
Here's the quick breakdown:
|
Feature
|
BOI (Beneficial Ownership Info)
|
RER (Real Estate Report)
|
|
Governing Rule
|
Corporate Transparency Act (CTA)
|
FinCEN Residential Real Estate Rule
|
|
Applies To
|
Reporting companies (LLCs, corps, etc.)
|
All-cash real estate transactions (entities)
|
|
Who Files
|
The entity itself
|
Title/settlement agent
|
|
Timing
|
30 days after entity creation/change
|
30 days after closing
|
|
Penalties
|
$500/day + criminal
|
Civil + criminal liability
|
|
Foreign Clients Affected?
|
✅ Yes
|
✅ Yes
|
Why it matters:
Foreign buyers using LLCs, trusts, or hybrid structures may be triggering both rules-often unknowingly.
That's where we come in.
At Foreign Tax CPA, we support title teams behind the scenes:
- BOI report prep for foreign-owned entities
- Trust & entity structure reviews
- Pre-closing risk flagging in international transactions
We don't just do FIRPTA-we do foreign.
------------------------------
Kat Rodgers
Foreign Tax CPA, LLC
Cocoa Beach FL
+1 (321) 784-8329
------------------------------