12/30/2024
I sent out a Christmas letter regarding the BOI (Beneficial Ownership Information) reporting on FinCEN under the CTA (Corporate Transparency Act). Well we have been on quite the roller coaster. First it had to be reported by January 1st 2025 for exciting businesses, prior to 2024. Then finally a lawsuit saying this was unconstitutional for the Nation.
Then on December 23rd, 2024 the 5th Circuit Court of Appeals reinstated the January 1st, 2025 deadline.
Then later the next day they changed the deadline:
1. BOI Reporting Deadlines Extended
Following the Fifth Circuit Court of Appeals' decision on December 23, 2024, reinstating the Corporate Transparency Act (CTA), FinCEN has issued updated deadlines for BOI reporting:
• Reporting companies created or registered before January 1, 2024: Deadline extended to January 13, 2025 (previously January 1, 2025).
• Reporting companies created or registered between September 4, 2024, and December 23, 2024: Deadline extended to January 13, 2025.
• Reporting companies created or registered between December 3, 2024, and December 23, 2024: Deadline extended by 21 days from their original deadline.
• Reporting companies created or registered on or after January 1, 2025: Must file within 30 days of their creation or registration.
• Disaster Relief Extensions: Companies qualifying for disaster relief may have deadlines that extend beyond January 13, 2025, and should follow the later date.
As of, December 27, 2024, at 9:30 ET, here is where BOI reporting stands:
• There is a temporary injunction against the reporting rule, again making BOI reporting discretionary nationwide.
• If the injunction is lifted, reporting companies formed before January 1, 2024, must file their initial report by January 13, 2025 (unless FinCEN grants another short extension).
So the question is what do you do, for the companies that want me to file, I can go on my forms and start to set it up... SO if they decide it is required we are ready to go. This is just crazy what is going on. How is the average person, let alone those of us in the field, suppose to keep track. I will do my best to watch this for you.
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