Insights

Beneficial Ownership Information Reporting Injunction Lifted,
Putting in Place a January 13, 2025 Filing Due Date for Most BOI Reports

The Fifth Circuit U.S. Court of Appeals put a “Stay” on the recent U.S. District Court beneficial ownership information reporting injunction in the Texas Top Cop Shop v. Garland et. al. case. On top of it all, late in the day, FinCEN issued filing deadline relief until January 13, 2025 for most entities. This means that for 90% of all legal entities (LLCs, corporations, etc.), there is a January 13, 2025, due date for filing a FinCEN Beneficial Ownership Information Report.

Below is a list of the revised reporting deadlines:

  • Reporting companies created or registered before Jan. 1, 2024, have until Jan. 13, 2025, to file initial BOI reports with FinCEN. (These companies would otherwise have been required to report by Jan. 1, 2025.)
  • Reporting companies created or registered in the United States on or after Sept. 4, 2024, that had a filing deadline between Dec. 3, 2024, and Dec. 23, 2024, have until Jan. 13, 2025, to file initial BOI reports with FinCEN.
  • Reporting companies created or registered in the United States on or after Dec. 3, 2024, and on or before Dec. 23, 2024, have an additional 21 days from their original filing deadline to file initial BOI reports with FinCEN.
  • Reporting companies that qualify for disaster relief may have extended deadlines that fall beyond Jan. 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 Jan. 1, 2025, have 30 days to file initial BOI reports with FinCEN after receiving actual or public notice that their creation or registration is effective.

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The information presented here should not be construed as legal, tax, accounting, or valuation advice. No one should act on such information without appropriate professional advice and after a thorough examination of the particular situation.