On December 23, 2024, the United States Fifth Circuit Court of Appeals issued a ruling effectively reinstating the Beneficial Ownership Information (BOI) reporting requirements under the Corporate Transparency Act (CTA). The United States Treasury Department’s FinCEN office later extended the BOI filing deadlines in light of the Fifth Circuit ruling.
Under the new filing deadlines, companies subject to the BOI filing requirements and created or registered before January 1, 2024 now have until January 13, 2025 to file their initial BOIs with FinCEN. Previously, they were required to file by January 1, 2025.
FinCEN also announced the following reporting deadlines:
- Companies created on or after September 4, 2024 that had an original filing deadline between December 3 and 23, 2024 must now file their BOIs by January 13, 2025.
- Companies created between December 3 and 23, 2024 have fifty-one (51) days from the date of formation to file their BOIs.
- Companies created on or after January 1, 2025 have thirty (30) days from the date of formation to file their BOIs.
As noted in our previous client alerts on this topic, additional litigation is expected on this issue, so these dates are subject to change. We will continue to deliver these updates as the regulatory landscape on the CTA filing requirements evolves.