BOI Report Update

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The Saga Continues

If you’re a business owner, you’ve likely heard some buzz about the Beneficial Ownership Information (BOI) report—a key component of the Corporate Transparency Act (CTA). Let’s break down the latest updates and what they mean for you.

Recap: Original Filing Deadlines

The BOI report was initially tied to the following deadlines:

• Businesses created before 2024: Filing deadline was January 1, 2025.

• Businesses created between January 1, 2024, and January 1, 2025: Filing was required 90 days after creation.

• Businesses created on or after January 1, 2025: Filing was due 30 days after creation.

However, recent legal developments have introduced significant changes to these requirements.

Key Updates

Here’s a timeline of recent events shaping the BOI report filing process:

• December 3, 2024:
  A Texas court issued a temporary injunction, halting enforcement of the CTA and the January 1, 2025, filing deadline. This made BOI filing voluntary as of that date. However, the Department of Justice, on behalf of the Treasury Department, appealed the decision.

• December 23, 2024:
  The appeal resulted in the CTA being ruled constitutional, lifting the temporary injunction. In response, FinCEN extended the filing deadlines.

• December 27, 2024:
  The U.S. Court of Appeals for the Fifth Circuit issued an order to vacate the previous ruling that lifted the injunction. As a result, BOI filing returned to being voluntary once again.

What’s Next?

While FinCEN is expected to extend the filing deadlines if the injunction is lifted, the length of the extension remains uncertain. Given this unpredictability—and the fact that this is a one-time filing—it’s wise to proceed with filing the BOI report proactively to ensure compliance regardless of future developments.

Staying ahead of regulatory requirements protects your business from potential headaches down the line. Don’t wait for more changes; take action now to secure your compliance.