On December 23, 2024, the Fifth Circuit Court of Appeals in Texas Top Cop Shop v. Garland issued an order lifting the district court’s December 3rd preliminary nationwide injunction on beneficial ownership information (BOI) reporting, pending a final resolution of the appeal. Later that day, FinCEN issued guidance on its website acknowledging the decision and granting various filing extensions, as follows:
- For entities created or registered before 2024, the filing deadline was extended from December 31, 2024 to January 13, 2025.
- For entities created or registered on or after September 4, 2024, the filing deadline was extended from December 3, 2024 to January 13, 2025.
- For entities created or registered on or after December 3, 2024 and on or before December 23, 2024, the filing deadlines were extended an additional 21 days from the regular filing deadlines.
Thus, BOI reporting is required again and affected businesses must complete their reporting by the new deadlines above. For entities created or registered before 2024, the new filing deadline is January 13, 2025.
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Please reach out to Withum’s Tax Services Team if you have any questions about your BOI reporting obligation.
