In major news related to the Corporate Transparency Act, beneficial ownership information reports (BOIR) are once again mandatory. The 5th Circuit Court of Appeals stayed the nationwide preliminary injunction issued by the U.S. District Court for the Eastern District of Texas that temporarily enjoined FinCEN’s enforcement of the beneficial ownership information reporting obligations.

Following the ruling from the 5th Circuit Court of Appeals, FinCEN issued an update and extended certain deadlines, as set forth below. All reporting companies that are required to file a beneficial ownership information report must do so by the applicable deadline. Please reach out to your Much attorney with any questions.

Updated FinCEN Beneficial Ownership Information Reporting Deadlines as of December 24, 2024

• Reporting companies created or registered prior to January 1, 2024 have until January 13, 2025 to file their initial beneficial ownership information reports with FinCEN. (These companies would otherwise have been required to report by January 1, 2025.)
• 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 beneficial ownership information reports with FinCEN.
• 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 beneficial ownership information reports with FinCEN.