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Update Regarding The Filing Of Beneficial Ownership Information Reports (“BOIR”)
  • Client Memos
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VERY TIME SENSITIVE!!

Last week we reported that the Financial Crimes Enforcement Network (FinCEN) ceased enforcement of the Beneficial Ownership Information Report (BOIR) filing requirements under the Corporate Transparency Act (“CTA”), due to a nationwide court injunction issued in the case of Texas Top Cop Shop, Inc. v. Garland.

Today the 5th Circuit Court of Appeals has reversed the stay, reinstating the compliance obligations under the Corporate Transparency Act (CTA) to file the BOIR. 

Prior to the injunction, the deadline to file a BOIR was January 1, 2025, for entities originally formed prior to January 1, 2024.

FinCEN has issued a statement that the deadline to file the BOIR has now been extended to January 13, 2025.

All BOIR filings that were originally due by January 1, 2025, must be filed no later than January 13, 2025, to avoid penalties for noncompliance.

Appeals in this case of Texas Top Cop Shop, Inc. v. Garland will likely continue, and we will continue to update you if there are further changes requiring the obligation to report.  As of today, we are again advising our clients to comply with the BOIR filing requirements by January 13, 2025.

If you have any questions, please do not hesitate to reach out to us.

Our previous articles regarding BOIR filing requirements can be found at:

November 25, 2024:   https://www.fbco.com/publications/new-reporting-requirements-under-the-corporate-transparency-act-2024/

December 16, 2024:   https://www.fbco.com/publications/court-halts-reporting-obligations-under-the-corporate-transparency-act/

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