Update 3/3/25: On March 2, 2025, the U.S. Department of the Treasury announced that it will no longer enforce the Corporate Transparency Act (CTA), effectively suspending the requirement for small businesses to register ownership information in the beneficial ownership information (BOI) database. Read the press release here. This follows the February 27th notice from FinCEN stating they would temporarily halt enforcement.
Update 2/18/25 : BOI reporting is back on. The US District Court granted a stay in the Smith v US DoT case, meaning that the Corporate Transparency Act (CTA) and the beneficial ownership information (BOI) reporting requirements under the CTA are now back in effect. Most companies have until March 21, 2025 to file. Read more.
Update 2/14/25: FinCEN updated guidance for filing deadlines in the event the current injunctions are stayed. For now, BOI reporting is still voluntary. However, if the government’s stay is granted, most businesses will have 30 days from the date the stay is granted to file. Read more
Update 1/24/25: On January 23, 2025, the US Supreme Court issued a ruling that lifted the nationwide injunction delaying the enforcement of Beneficial Ownership Information reporting under the Corporate Transparency Act. FinCEN has clarified that this new ruling conflicts with a prior block meaning BOI reporting requirements are still on hold. Read more
UPDATE 1/2/25: A second panel from the Fifth Circuit Court of Appeals overturned its ruling (12/23/24) on December 26th, 2024. As of 12/26/24, no businesses are required to file Beneficial Ownership Information reports to FinCEN. Read more.
On Monday, December 23rd, the Fifth Circuit Court of Appeals has reinstated Beneficial Ownership Information (BOI) reporting requirements for small businesses under the Corporate Transparency Act (CTA). This decision overturns the previous injunction made on December 3rd.
In response to the ruling, FinCEN announced extended deadlines for BOI filing. The following information comes from FinCEN’s latest alert:
- 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.)
- Reporting companies created or registered in the United States on or after September 4, 2024 that had a filing deadline between December 3, 2024 and December 23, 2024 have until January 13, 2025 to file their initial beneficial ownership information reports with FinCEN.
- Reporting companies created or registered in the United States on or after December 3, 2024 and on or before December 23, 2024 have an additional 21 days from their original filing deadline to file their initial beneficial ownership information reports with FinCEN.
- Reporting companies that qualify for disaster relief may have extended deadlines that fall beyond January 13, 2025. These companies should abide by whichever deadline falls later.
- Reporting companies that are 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 after receiving actual or public notice that their creation or registration is effective.
Wegner CPAs tax and business advisors put together a list of BOI reporting resources for small businesses that may need more guidance.
Note – please contact your attorney/legal counsel if you need help filing this online report. Wegner CPAs is prevented from filing this report for your business/LLC.
