FinCEN Issues New Guidance on Beneficial Ownership Information (BOI) Reporting Deadlines
As of December 23, 2024, the U.S. Court of Appeals for the Fifth Circuit issued a stay of the nationwide preliminary injunction previously granted by the U.S. District Court for the Eastern District of Texas in the case of Texas Top Cop Shop, Inc., et al. v. Garland, et al., No. 4:24-cv-00478 (E.D. Tex.). This decision effectively reinstates the Corporate Transparency Act (CTA) and its Beneficial Ownership Information (BOI) reporting requirements nationwide, pending the Department of the Treasury’s appeal resolution.
Key Updates on BOI Reporting Deadlines:
1.
General Reporting Deadline Extensions:
- Pre-2024 Entities: Reporting companies created or registered before January 1, 2024, now have until January 13, 2025, to file their initial BOI reports. (The Original deadline was January 1, 2025.)
- Post-September 4, 2024, Entities: Companies created or registered on or after September 4, 2024, with filing deadlines between December 3, 2024, and December 23, 2024, also have until January 13, 2025, to file their initial reports.
2.
Entities Created During the Injunction Period:
Companies created or registered between December 3, 2024, and December 23, 2024, have an additional 21 days from their original deadline to file their BOI reports.
3.
2025 and Beyond Reporting Requirements:
Reporting companies created or registered in the U.S. on or after January 1, 2025, must file their BOI reports within 30 days of receiving actual or public notice of their creation or registration becoming effective.
For more information regarding FinCEN’s guidance, please visit FinCEN’s BOI Resource Page.
If you require assistance or support with the CTA – BOI report filings, please contact Jackellyn T. Davis, Head of Corporate and Regulatory Compliance at Doss Law, at Jackellyn@DossLaw.com.
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