Following a December 23, 2024, federal Court of Appeals decision, most reporting companies are once again required to file Beneficial Ownership Information (BOI) with FinCEN. To account for the period of uncertainty caused by the injunction, the Treasury Department has extended certain filing deadlines:

➡️ Created/Registered Before January 1, 2024: Deadline extended to January 13, 2025 (originally January 1, 2025).

➡️ Created/Registered Between September 4 and December 23, 2024: New deadline is January 13, 2025.

➡️ Created/Registered Between December 3 and December 23, 2024: Additional 21 days beyond the original filing deadline.

➡️ Disaster Relief: Deadlines may extend beyond January 13, 2025; use the later applicable date.

Update December 27:

From FinCEN:

“On December 26, 2024, a different panel of the U.S. Court of Appeals for the Fifth Circuit issued an order vacating the Court’s December 23, 2024 order granting a stay of the preliminary injunction. Accordingly, as of December 26, 2024, the injunction issued by the district court in Texas Top Cop Shop, Inc. v. Garland is in effect and reporting companies are not currently required to file beneficial ownership information with FinCEN.”

Given the uncertainty arising from this continued litigation and appeal process, we encourage our clients to still consider filing their BOI report voluntarily in the event reporting becomes mandatory.