December 26, 2024
On December 23, 2024, the Fifth Circuit Court of Appeals reinstated the obligation of reporting companies to file their Beneficial Ownership Information (BOI) reports with the Financial Crimes Enforcement Network (FinCEN).
Following the court’s decision, FinCEN announced a filing deadline extension to January 13, 2025, for those companies whose initial BOI reports were originally required to be filed by January 1, 2025. The extension was granted because the Treasury recognized that reporting companies may need additional time to comply given the previous court decision that suspended reporting requirements.
Several court cases across the country continue to litigate the constitutionality of the Corporate Transparency Act (CTA). But in their ruling, the Fifth Circuit Court said that “the government has made a strong showing that it is likely to succeed on the merits in defending the CTA’s constitutionality.”
Summary of new BOI Reporting Deadlines
Reporting Company Description |
New BOI Reporting Deadline |
Reporting companies created or registered before January 1, 2024 |
January 13, 2025 |
Reporting companies created or registered on or after September 4, 2024 that had a filing deadline between December 3, 2024 and December 23, 2024 |
January 13, 2025 |
Reporting companies created or registered between December 3, 2024 and December 23, 2024 |
Additional 21 days from their original filing deadline |
Reporting companies created or registered on or after January 1, 2025 |
30 days after receiving actual or public notice that their creation or registration is effective |