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What's Going on With BOI Reporting Requirements?

The Beneficial Ownership Information (BOI) reporting requiremements are again on hold resulting from the second nationwide injunction preventing the enforcement of the Corporate Transparency Act (CTA) and its BOI reporting requirements. While "Reporting Companies" (as defined in the CTA) are not currently required to file BOI reports, they may still do so voluntarily. (Learn more about the CTA and BOI here.) Here's what you need to know.


Quick Recap for the Lay Person

As of January 1, 2024, the CTA required most corporations, limited liability companies (LLCs), and similar entities to file BOI reports to the Financial Crimes Enforcement Network (FinCEN). The purpose behind the CTA and the BOI reports is to enhance transparency and combat financial crimes like money laundering and tax evasion.


Beginning on or around January 1, 2024, businesses began filing their reports with the recognition that if they didn't do so before the end of 2024, their business could be hit with substantial civil and criminal penalties.


December 3, 2024: 1st nationwide injunction prohibiting the US Treasury Department from enforcing the BOI requirement. The BOI reporting requirements became voluntary.

December 23, 2024: Court issued a stay on the injunction, requiring that the BOI reporting requirements again be mandatory. The reporting deadline was extended from January 1, 2025 to January 13, 2025.


December 26, 2024: 2nd nationwide injunction against the BOI reporting requirements. Businesses may voluntary report their BOI, but they are not required to do so...at least until further notice.


What Should You Do?

If your business would qualify as a Reporting Company under the CTA, it would be prudent to continue to gather the information that you would need to file a BOI report in case the injunction is stayed and the reporting requirements become mandatory...again.


If the BOI reporting requirements are reinstated, it is reasonable - though not guaranteed - to expect that there will be an extended deadeline and/or a grace period to accommodate the rollercoaster that businesses have been on.


No one knows what is to come of the BOI reporting requirements. Should the BOI reporting requirements become mandatory again, businesses that fail to comply may face significant civil and criminal penalties. So it's best to be prepared.




For more details, visit FinCEN’s official BOI filing page.

Questions? Schedule a consultation with Ariella Law.


The information on this website is for informational purposes only, and does not constitute legal advice.





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