ARTICLE
In a somewhat surprising move, the Fifth Circuit granted the Department of Justice’s request to stay (or stop) the preliminary injunction that was pausing the Corporate Transparency Act (CTA)’s implementation. There are a lot of double negatives in there, but the bottom line – for today – is that Beneficial Ownership Information (“BOI”) filings are once again due by the end of this year. Everyone who has not filed yet is must do so by the following revised deadlines: Reporting companies that were created or registered in the United States 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. Reporting companies that qualify for disaster relief may have extended deadlines that fall beyond January 13, 2025. These companies should abide by whichever deadline falls later. Please note that the following deadlines to file beneficial ownership information reports have remained unchanged: Reporting companies that are created 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 that their creation or registration is effective. After an initial beneficial ownership information report is filed and on a going-forward basis, applicable reporting companies will be required to provide updates to FinCEN concerning information covered in the report within 30 days of the date the change occurred. For more information about the Corporate Transparency Act and its reporting requirements, please visit FinCEN’s website located at www.fincen.gov/boi. The above information has been provided by ECA member firm Couch White, LLP. You are encouraged to consult your own attorney with any questions you may have as to your company’s reporting requirements.
In a somewhat surprising move, the Fifth Circuit granted the Department of Justice’s request to stay (or stop) the preliminary injunction that was pausing the Corporate Transparency Act (CTA)’s implementation. There are a lot of double negatives in there, but the bottom line – for today – is that Beneficial Ownership Information (“BOI”) filings are once again due by the end of this year.
Everyone who has not filed yet is must do so by the following revised deadlines:
Please note that the following deadlines to file beneficial ownership information reports have remained unchanged:
For more information about the Corporate Transparency Act and its reporting requirements, please visit FinCEN’s website located at www.fincen.gov/boi.
The above information has been provided by ECA member firm Couch White, LLP. You are encouraged to consult your own attorney with any questions you may have as to your company’s reporting requirements.