Updated 2/19/2025:
The Financial Crimes Enforcement Network (FinCEN) announced that beneficial ownership information (BOI) reporting requirements are back in effect. This comes after the February 18, 2025 decision by the U.S. District Court for the Eastern District of Texas in Smith, et al. v. U.S. Department of the Treasury, et al. The new deadline for most reporting companies will be March 21, 2025. FinCEN will assess options to possibly modify other deadlines as they prioritize reporting for entities with the most significant risk to national security. The agency plans to create a process to review and possibly revise BOI reporting rules so that many U.S. small businesses, who are lower-risk entities, aren’t unduly burdened.
Updated 12/27/2024:
The Fifth Circuit Court has reinstated the stay on enforcement of the Corporate Transparency Act (CTA). As a result, Beneficial Ownership Information (BOI) reporting companies organized prior to 1/1/2024 are not currently subject to either the original deadline of 1/1/2025 or the updated deadline of 1/13/2025 outlined by FinCEN. Consult with your legal and financial advisors to determine your best path forward as the case plays out in court.
Entities that are considered reporting companies, with some exceptions, are once again required to file beneficial ownership information (BOI) with FinCEN, a federal Court of Appeals ruled on December 23, 2024. Reporting companies have new deadlines to file based on their creation or registration date. Originally, the first wave of reporting companies was expected to file their reports by January 1, 2025, but the Department of the Treasury has granted additional time to comply.
Updated Deadlines for Beneficial Ownership Information (BOI) Reports
Consult with the lawyer who helped you set up the entity and your financial advisors for a detailed plan of action. If you are a reporting company, you should take this time to review BOI report requirements with your financial and legal team to ensure your compliance. The plaintiffs in National Small Business United v. Yellen aren’t currently required to submit BOI reports to FinCEN.
The new deadlines for applicable reporting companies are as follows:
- Reporting companies created or registered before January 1, 2024:
- Reporting companies created or registered in the United States on or afterSeptember 4, 2024, with a filing deadline between December 3, 2024, and December 23, 2024:
- Reporting companies created on or afterDecember 3, 2024 and on or beforeDecember 23, 2024:
- Eligible for an additional 21 days from your original filing deadline
- Reporting companies eligible for disaster relief may have extended deadlines beyond January 13, 2025.
- Adhere to the later of the two deadlines
- Reporting companies 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 once they’ve received actual or public notice that their creation or registration is effective.
Anders Tax advisors work with businesses to keep them in compliance with ever-changing financial regulations. Learn more about our services and the associated fees by requesting a meeting with an Anders advisor below.
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