NEW LEGAL UPDATE: ON DECEMBER 27, 2024, FINCEN ANNOUNCED THE FILING DEADLINE FOR BOI REPORTS IS SUSPENDED AGAIN. FILING IS VOLUNTARY.
MAKE SURE YOU READ THE NEW LEGAL UPDATE AND STAY UP TO DATE WITH THE ONGOING LITIGATION.
URGENT: A FEDERAL APPELLATE COURT REINSTATED ENFORCEMENT OF THE CORPORATE TRANSPARENCY ACT. FOR MOST, THE DEADLINE TO REPORT BENEFICIAL OWNERSHIP INFORMATION IS JANUARY 13, 2025.
On December 23, 2024, a federal appellate court reinstated the filing requirements under the Corporate Transparency Act (“CTA”). Following the appellate court’s decision, any covered entity is once again required to report certain information about the entity and its beneficial owners to the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN).
Following the appellate court’s decision, FinCEN released a statement on its website extending certain reporting deadlines:
• Reporting companies formed or registered before January 1, 2024, have until January 13, 2025, to file their initial beneficial ownership information reports with FinCEN.
• Reporting companies formed or registered in 2024 must generally submit BOI reports within 90 days of the company’s creation or registration.
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- For companies formed or registered on or after September 4, 2024, the deadline to submit initial BOI reports has been extended to January 13, 2025.
- For companies formed or registered on or after December 3, 2024, and on or before December 23, 2024, the deadline to submit initial BOI reports has been extended 21 days from whenever the initial filing deadline would otherwise have been.
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• Reporting companies formed or registered on or after January 1, 2025, must submit a BOI report within 30 days after receiving notice of the company’s creation or registration, as was the case before the injunction.
Since the CTA’s reporting requirements are back in effect, entities should immediately assess whether they are classified as a “reporting company,” and if so, act expeditiously to complete and file BOI reports with FinCEN before the applicable deadline.
Where can you find more information?
BOI Small Compliance Guide v1.1 (fincen.gov)
Beneficial Ownership Information Reporting | FinCEN.gov
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