Corporate Transparency Act BOIR filing requirements back in place.
After a brief pause, filing requirements are back in place for small businesses. Due to the Fifth Circuit Court of Appeals decision issued on December 23rd granting a stay of the preliminary injunction enjoining the Corporate Transparency Act (CTA) entered in the case of Texas Top Cop Shop, Inc. v. Garland. The final outcome of the Department of the Treasury's ongoing appeal of the district court's order is yet to be determined, but for now reporting companies are once again required to file beneficial ownership information reports (BOIR).
The Department of the Treasury recognized that reporting companies may need additional time because of the brief pause caused by the preliminary injunction, and are extending the reporting deadlines as follows:
- Entities Formed Before January 1, 2024 - have until January 13, 2025, to file their initial BOIR reports.
- Entities Formed Between September 4 and December 23, 2024 - have until January 13, 2025, to file their reports.
- Entities Formed Between December 3 and December 23, 2024: These entities have 21 extra days beyond their original filing deadline to submit their BOIR reports.
- Entities Qualifying for Disaster Relief: Companies eligible for disaster relief may have extended deadlines beyond January 13, 2025, and should comply with the later applicable date.
If you haven't filed yet, you need to make sure it gets done prior to the new deadlines. Civil penalties can reach up to $591 a day for late filing and in the case of criminal penalties fines over $10,000 and/or imprisonment of up to two years. These penalties can be applied to individuals required to report and reporting entities.
You can file easily at this website: https://boiefiling.fincen.gov/