Uncertain About the Reporting Deadlines for BOI? This Article Will Bring You Up to Date
Back in 2021 Congress passed the Corporate Transparency Act (CTA) which included the Beneficial Ownership Information (BOI) reporting requirements for certain companies beginning in 2024. Companies in business before 2024 had a reporting deadline of January 1, 2025, while new companies created in 2024 had a 90-day reporting requirement. CTA’s reporting requirements are intended to combat money laundering, tax fraud and the financing of terrorism. Less than a month before the January 1, 2025, filing due date, a series of events took place that has left in doubt the filing due date and even whether the CTA is Constitutional. Here is the history of those events:
On December 3, 2024, the U.S. District Court for the Eastern District of Texas issued a nationwide injunction that temporarily halted enforcement of the CTA and its Beneficial Ownership Information (BOI) reporting requirements with the Financial Crimes Enforcement Network (FinCEN) based on the CTA being unconstitutional under the Commerce Clause or Necessary and Proper Clause.
On December 5, 2024,in response to the Texas court’s ruling, the Department of Justice filed a Notice of Appeal requesting a stay of the injunction pending appeal.
On December 23, 2024,the Fifth Circuit Court of Appeals lifted the injunction for all companies except the plaintiffs in the December 3 Texas District Court Case.
On December 26, 2024, the stay was reinstated by the Fifth Circuit Court of Appeals pending a hearing scheduled for March 25, 2025,again suspending the BOI filing deadlines of companies with FinCEN.
On December 31, 2024,the Department of Justice (DOJ),filed with the Supreme Court (SCOTUS) asking the high court to stay the district court’s injunction, reasoning that the government “is likely to succeed on the merits of respondents’ claim” and that the Corporate Transparency Act’s reporting requirements are important to the federal response to money laundering, tax fraud and the financing of terrorism, falling “comfortably within Congress’s authority under the Commerce Clause to regulate economic activities that substantially affect interstate commerce.” As of the date of this article, SCOTUS has not taken any action.
On January 15, 2025, Senator Tommy Tuberville (R-AL) reintroduced the Repealing Big Brother Overreach Act that would overturn the CTA, and thus make filing a BOI report unnecessary. At the same time Congressman Warren Davidson (R. OH) also reintroduced companion legislation in the U.S. House of Representatives.
On January 23, 2025, the Supreme Court issued a stay on a nationwide injunction that had previously halted the enforcement of beneficial ownership information (BOI) reporting requirements. The stay will remain in effect until the Fifth Circuit acts and possibly further review by the Supreme Court.
On January 24, 2025, FinCEN provided the following update: “On January 23, 2025, the Supreme Court granted the government’s motion to stay a nationwide injunction issued by a federal judge in Texas (Texas Top Cop Shop, Inc. v. McHenry—formerly, Texas Top Cop Shop v. Garland). As a separate nationwide order issued by a different federal judge in Texas (Smith v. U.S. Department of the Treasury) remains in place, reporting companies are not currently required to file beneficial ownership information with FinCEN despite the Supreme Court’s action in Texas Top Cop Shop. Reporting companies are also not liable if they fail to file this information while the Smith order remains in force. However, reporting companies may continue to voluntarily submit beneficial ownership information reports.”
Companies Subject to BOI Reporting - Generally, CTA requires the following companies to report BOI:
A corporation,
A limited liability company, or
Any other entity created by the filing of a document with a secretary of state or any similar office under the law of a state or Indian tribe. This generally includes limited partnerships and possibly general partnerships depending upon state or tribal law.
A Foreign corporation, limited liability company, or other entity formed under the law of a foreign country AND registered to do business in any U.S. state or in any Tribal jurisdiction, by the filing of a document with a secretary of state or any similar office under the law of a U.S. state or Indian tribe.
The Current Status - As a beneficial owner of a company that is subject to the BOI reporting requirement and as of January 24, 2025, the date of this article:
The reporting requirement remains suspended.
When the first injunction was lifted FinCEN extended the filing due date. There is no reason to believe they won’t do that again should, and if, the injunction is again lifted. However, the extension FinCEN was going to provide was for less than two weeks, so if the BOI reporting requirement is reinstated, expect that any extended deadline will only be for a short time.
If you already have completed the BOI reporting requirements there is nothing to be concerned about. However, should the reporting requirement be reinstated, remember that there is also a requirement to update the information should there be any changes.
FinCEN has indicated that BOI reporting is still being accepted on their website should you wish to get the original reporting completed and not have to worry about deadlines if the requirement is reinstated.
Stay Tuned! Please contact this office with questions.
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