Urgent Update on BOI Filing Requirements – Filing Now Required

Urgent Update on BOI Filing Requirements – Filing Now Required

Days after a judge in Texas ruled that a nationwide preliminary injunction barring FinCEN from enforcing the Corporate Transparency Act (CTA) would stand, the U.S. Court of Appeals for the Fifth Circuit has declared the opposite. In a December 23, 2024 ruling, a unanimous Fifth Circuit bench granted the government’s emergency motion for a stay pending the appeal.

The reversal means that the businesses that are required to file BOI reports must now do so during the appeal process.

In response to the Court decision, the Financial Crimes Enforcement Network (FinCEN) has granted a short extension.

Extended Deadlines for Existing Companies
Companies created or registered before January 1, 2024, must file their initial BOI reports by January 13, 2025 (extended from January 1, 2025).

Extensions for Recently Registered Companies
Companies registered between September 4, 2024, and December 23, 2024, now have until January 13, 2025, to file their BOI reports.

Companies registered between December 3, 2024, and December 23, 2024, receive an additional 21 days from their original filing deadline.

Disaster Relief Extensions
Depending on their circumstances, companies qualifying for disaster relief may have filing deadlines beyond January 13, 2025.

New Companies Starting in 2025
Companies registered on or after January 1, 2025, must file their BOI reports within 30 days of their creation or registration becoming effective.

You can find information and file your BOI reports at www.boiefiling.fincen.gov.

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