On February 18, 2025, the U.S. Court of Appeals for the Fifth Circuit reinstated the implementation of the Corporate Transparency Act, including the requirement for entities to file a Beneficial Ownership Information Report (BOI Report) with the Financial Crimes Enforcement Network (FinCEN).
FinCEN announced that it is extending the filing period for most reporting companies to March 21, 2025. Entities formed on or after the reinstatement must file a BOI Report within 30 days of formation.
What is the Corporate Transparency Act?
Click here to see our previous update that provides a summary of the CTA, and a description of the types of entities that are required to file BOI Reports with FinCEN.
What does this mean for my requirement to register?
Reporting companies should file any required BOI Reports before the applicable deadline. Congress is considering a bill that extends the BOI Report deadline for entities formed before 2024 to January 1, 2026, but it is unclear whether this will be enacted. Accordingly, we recommend submitting any previously unfiled BOI Reports no later than March 21, 2025, and submitting BOI Reports for newly-formed entities within 30 days of formation.
For more information about the Corporate Transparency Act, or how these latest developments affect your requirement to file a BOI Report, please contact members of our Business Group Team, including Barry Ziker, Dan Goodrich, Derek Woolston, Michael Edwards, Matthew Weger, and Robert Van Cleve.
The information contained in this update is provided for informational purposes only. It should not be construed as business, legal, accounting, tax, financial, investment or other advice on any matter and should not be relied upon as such.