Game (Back) On; 5th Circuit Restores BOI Reporting Requirements
In a recent (and honestly frustrating) turn of events, the Fifth Circuit Court of Appeals granted the Department of Justice’s emergency motion to stay the nationwide preliminary injunction issued by the Texas federal lower court regarding the Beneficial Ownership Information reporting requirements under the Corporate Transparency Act (CTA). However, perhaps as a Christmas present (but more likely due to the jammed timeline), the Financial Crimes Enforcement Network (FinCEN) has extended the reporting deadlines as follows:
Reporting companies that were created or registered prior to January 1, 2024 have until January 13, 2025 to file their initial beneficial ownership information reports with FinCEN. (These companies would otherwise have been required to report by January 1, 2025.)
Reporting companies created or registered in the United States on or after September 4, 2024 that had a filing deadline between December 3, 2024 and December 23, 2024 have until January 13, 2025 to file their initial beneficial ownership information reports with FinCEN.
Reporting companies created or registered in the United States on or after December 3, 2024 and on or before December 23, 2024 have an additional 21 days from their original filing deadline to file their initial beneficial ownership information reports with FinCEN.
Reporting companies that qualify for disaster relief may have extended deadlines that fall beyond January 13, 2025. These companies should abide by whichever deadline falls later.
Reporting companies that are created or registered in the United States on or after January 1, 2025 have 30 days to file their initial beneficial ownership information reports with FinCEN after receiving actual or public notice that their creation or registration is effective.
We’re happy to help any companies that have not yet completed their BOI reporting requirements under the CTA. Please reach out to us if you need assistance or have any questions. We’re here to help.