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Injunction has been Lifted and Due Date for Corporate Transparency Act for existing entities is now January 13, 2025

The US Court of Appeals has lifted the injunction that previously blocked enforcement of and compliance with the Corporate Transparency Act. Accordingly, companies are now required to file a Beneficial Ownership Information Report with FinCEN, unless they are otherwise exempt.

If you are required to file for any existing companies, you may file the beneficial ownership information (“BOI”) report with FinCEN directly on the FinCEN website, https://fincen.gov/boi, or alternatively, we will do our best to assist you.

Currently the Department of the Treasury has extended the reporting deadlines as follows:

  1. Pre-2024 Entities: Reporting companies that were created or registered prior to January 1, 2024 have until January 13, 2025 to file their initial BOI reports with FinCEN. (These companies would otherwise have been required to report by January 1, 2025.)
  2. Entities Registered Between September 4, 2024, and December 2, 2024: Reporting companies created or registered in the United States on or after September 4, 2024 that had a filing deadline between December 3, 2024 and December 23, 2024 have until January 13, 2025 to file their initial BOI reports with FinCEN.
  3. Entities Registered Between December 3, 2024, and December 23, 2024: Reporting companies created or registered in the United States on or after December 3, 2024 and on or before December 23, 2024 have an additional 21 days from their original filing deadline to file their initial BOI reports with FinCEN, an extension to the original requirement to file within 90 calendar days.
  4. Disaster Relief: Reporting companies that qualify for disaster relief may have extended deadlines that fall beyond January 13, 2025. These companies should abide by whichever deadline falls later.

If you have already filed, please note that you do not need to re-file. You will only be required to file an amendment if there have been changes to the information contained in your report.

Please note that any reporting companies created on or after January 1, 2025 will only have 30 days to file their initial BOI reports with FinCEN after receiving actual or public notice that their creation or registration is effective.

If you have questions about the ruling or would like us to assist with your BOI submission, please contact us at CTA@coblentzlaw.com.