On December 23, 2024, the U.S. Court of Appeals for the Fifth Circuit granted a stay of the previously issued nationwide injunction in Texas Top Cop Shop, Inc., et al. v. Garland, et al., which had the effect of reinstating the Corporate Transparency Act (CTA) and its beneficial ownership information (BOI) reporting requirements. This development means that most reporting companies are, once again, required to file their beneficial ownership information with FinCEN, but in the spirit of holiday giving, FinCEN has provided modified deadlines to accommodate the period during which that injunction was in place.
FinCEN has established the following extended reporting deadlines:
- For companies created or registered before January 1, 2024: The deadline has been extended to January 13, 2025 (previously January 1, 2025);
- For companies created or registered on or after September 4, 2024, with original filing deadlines between December 3-23, 2024: The new deadline is January 13, 2025;
- For companies created or registered between December 3-23, 2024: The new deadline is an additional 21 days from their original filing deadline; and
- For companies created or registered on or after January 1, 2025: The standard 30-day filing requirement remains in effect after receiving notice of effective creation or registration.
Given the reinstatement of the CTA's reporting requirements and the newly established deadlines, it’s time to continue with your BOI filing preparations.
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