Beneficial Ownership Information Reporting Required Again
UPDATED: BOI Filing Deadline Slightly Extended
Jeff Storch | 12.23.24
This article was updated on 12/24/2024 to include information on FinCEN’s subsequent extension of the filing deadline.
On December 23, 2024, the Fifth Circuit of the United States Court of Appeals granted the Federal government’s motion for a temporary stay of the lower court’s order and injunction that had paused enforcement of the Corporate Transparency Act (CTA), as was described in our prior article. Without addressing the Fifth Circuit’s analysis here, its order means that reporting companies again are required to file beneficial ownership information (BOI) reports under the CTA.
In response, the Department of the Treasury later that day granted a slight extension to the BOI reporting deadlines, as follows:
- Reporting companies created or registered prior to January 1, 2024, have until January 13, 2025, to file their reports. (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 reports.
- 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.
The Department also noted that reporting companies that qualify for disaster relief may have extended deadlines that fall beyond January 13, 2025.
For entities waiting to file, time is quickly running out. See our recent article on the reporting deadline for a discussion on the reporting requirements, including what needs to be reported and where.
If you have questions on BOI reporting requirements, please contact the primary Boardman Clark attorney with whom you work or call us at (608) 257‑9521 and we will connect you with one of our business attorneys. Our firm does not intend to file BOI reports but can assist you in determining your filing obligations and information on third-parties who provide BOI filing services.
DISCLAIMER: The information provided is for general informational purposes only. This post is not updated to account for changes in the law and should not be considered tax or legal advice. This article is not intended to create an attorney-client relationship. You should consult with legal and/or financial advisors for legal and tax advice tailored to your specific circumstances.