Beneficial Ownership Reporting Deadline REINSTATED – Reports Due January 1, 2025

For the past few weeks, small business owners, individuals and other entities subject to the Beneficial Ownership Reporting Requirements (“BOIR”) under the Corporate Transparency Act (“CTA”) were relieved of the obligation to report such information to FinCEN due to the stay of the deadline which resulted from a federal court order in the Eastern District of Texas.

But since the December 3rd order, the government appealed the order issued by the Texas district court judge to the Fifth Circuit seeking to lift the stay on injunction staying the reporting deadline. The government requested that the Fifth Circuit issue its ruling by December 27th to provide entities subject to the reporting requirement time to comply by the January 1, 2025 deadline. Today, December 23rd, the Fifth Circuit issued its ruling. The Fifth Circuit has granted the government’s request for a stay and has reinstated the January 1, 2025 deadline for reporting companies to file their BOIR on the FinCEN website.

If they have not already done so, reporting companies should act quickly to gather the information that is required by the BOIR and file the required report via FinCEN’s website by the January 1, 2025 deadline.