BOI Reporting Requirements: A Timeline of Recent Changes
Last Updated: December 28, 2024
The Corporate Transparency Act's Beneficial Ownership Information (BOI) reporting requirements have undergone several significant changes in recent weeks.
📖[What is the BOI Filing and Corporate Transparency Act (CTA)]
Here's a comprehensive timeline of events, with the most recent developments first:
December 26, 2024: BOI Reporting Requirements Back on Hold
The Fifth Circuit Court of Appeals has vacated its previous stay, effectively putting BOI filing requirements back on hold. Key implications:
All reporting deadlines, including the January 13, 2025 compliance date, are now suspended
FinCEN will provide updated guidance once legal issues are resolved
No penalties will be enforced during this period of uncertainty
December 23, 2024: Fifth Circuit Reinstates BOI Requirements
The U.S. Court of Appeals for the Fifth Circuit temporarily lifted the nationwide injunction, briefly reinstating reporting requirements with adjusted deadlines:
Pre-2024 entities: Extended deadline to January 13, 2025
Entities created/registered between September 4-December 3, 2024: January 13, 2025 deadline
Entities created/registered December 3-23, 2024: 21-day extension from original deadline
Post-January 1, 2025 entities: 30 days from creation/registration notice
Special exemption: National Small Business United v. Yellen plaintiffs remain exempt
December 3, 2024: Nationwide Injunction Issued
📖[More about the Dec 3, 2024 Injunction]
The U.S. District Court for the Eastern District of Texas issued a nationwide injunction:
Halted enforcement of the Corporate Transparency Act
FinCEN confirmed compliance with the injunction
Suspended requirement for reporting companies to file beneficial ownership information
No penalties for failing to file during the injunction period
Important Considerations for Businesses
Despite the current hold on requirements, businesses should consider:
Preparedness Strategy
Gather necessary information now to be ready for potential quick turnaround
Review entity structure and beneficial ownership details
Consider voluntary filing to ensure compliance regardless of outcome
Potential Penalties When Reinstated
Civil penalties: $591 per day
Criminal fines: Up to $10,000
Potential imprisonment: Up to two years
Best Practices
Monitor FinCEN updates regularly
Maintain documentation readiness
Consider filing proactively if privacy concerns are minimal
Keep track of applicable deadlines and extensions
Need Help With BOI Filing?
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How to navigate the FinCEN website
Complete walkthrough of the filing process
Tips for gathering required information
Common pitfalls to avoid
Expert insights on compliance requirements
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