On Monday, Dec. 23, the 5th Circuit Court of Appeals overturned the lower court injunction that had temporarily halted enforcement of the Beneficial Ownership Information (BOI) reporting requirements under the Federal Corporate Transparency Act. As a result, most privately owned entities (corporations, LLCs, partnerships and limited partnerships) must report their BOI or face potential fines and penalties. The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) has extended the filing deadline for entities formed prior to Jan. 1, 2024, by 12 days as a result of the lawsuit. The original deadline was Jan. 1, 2025. According to FinCEN’s website: Beneficial Ownership Information Reporting | FinCEN.gov, the new deadline is Jan. 13, 2025. While the National Federation of Independent Business has stated that it plans to further appeal the decision, as of now, BOI reporting is once again the law of the land.
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.)
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