In a significant development, a federal Court of Appeals has lifted the nationwide preliminary injunction that had previously prevented FinCEN from enforcing the beneficial ownership information (BOI) reporting requirements of the Corporate Transparency Act (CTA).
FinCEN has kindly extended some filing deadlines for BOI reports, as detailed on their website. Reporting companies 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 have otherwise been required to report by January 1, 2025.
Reporting companies created or registered in the United States on or after September 4, 2024, with a filing deadline between December 3, 2024, and December 23, 2024, also have until January 13, 2025, to file their initial beneficial ownership information reports with FinCEN.
Additionally, reporting companies created or registered in the United States on or after December 3, 2024, and on or before December 23, 2024, have been granted 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 beyond January 13, 2025. In such cases, they should adhere to the later deadline.
Reporting companies established 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 of their effective creation or registration.
We had previously advised that, unless you have specific circumstances, you should proceed with the filings despite the temporary injunction. Please allow at least four business days to review and prepare the necessary information for the filing.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
