From: Thomas J. O’Toole, Jr.
Date: December 26, 2024
Corporate Transparency Act – Beneficial Ownership Information Reporting
UPDATE: Extended Deadline on Beneficial Ownership Information Reporting Requirement
We want to bring to your attention two important updates on the Beneficial Ownership Information (“BOI”) reporting requirement:
On December 23, 2024, the United States Court of Appeals for the Fifth Circuit lifted the nationwide preliminary injunction on enforcement of the Corporate Transparency Act (“CTA”), which had been issued by the United States District Court for the Eastern District of Texas on December 3, 2024. This means that the CTA BOI reporting requirements and deadlines are back in effect.
FinCEN has extended the BOI Reporting deadlines:
- 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.
If you have any questions, concerns, or would like assistance with filing your company’s BOI report, please contact:
Laura Reeves
Senior Counsel
[email protected]
Jaylene M. Tinerella
Paralegal
jtinerella@mickesotoole
