BOI Reporting Updates
Treasury Department Comments on BOI Reporting
March 21, 2025
Once again, late week updates regarding Beneficial Ownership Information (BOI) reporting was issued through the Department of the Treasury’s Financial Crimes Enforcement Network. The full “Interim Final Rule” update can be viewed here but here are the main points for business owners:
- All entities created in the U.S. — including those previously known as “domestic reporting companies” — and their beneficial owners are exempt from reporting requirements.
- Only entities that are formed under the law of a foreign country and that have registered to do business in the U.S.
- FinCEN intends to finalize this rule yet this year.
We will continue to update BOI reporting information on this page as we learn more. Please bookmark it to more easily check back for updates.
Treasury Department Comments on BOI Reporting
March 3, 2025
Over the weekend, the Treasury Department commented through X (formerly Twitter) on the Corporate Transparency Act and the related Beneficial Ownership Information (BOI) reporting. The full posts can be viewed here but a quick look at the highlights of their comments are:
- It will not enforce any penalties or fines associated with BOI reporting under existing regulations.
- It will not enforce any penalties against U.S. citizens or the related beneficial owners after forthcoming rule changes take effect.
- Treasury is intending to narrow the focus to foreign-owned companies only.
- In related BOI comments, President Trump is supportive of this new direction.
We will continue to update BOI reporting information on this page as we learn more. Please bookmark it to more easily check back for updates.
Deadline on Hold (Again): Beneficial Ownership Information (BOI) Reporting
February 28, 2025
Once again, a change has occurred to the BOI reporting requirements. On Thursday, February 27, the Financial Crimes Enforcement Network (FinCEN) announced that they will extend the current BOI reporting requirements deadline. They also said they are working to reduce regulatory burden and will develop new regulations. A new deadline has not been announced but FinCEN said they will do so by March 21.
We will continue to update this page as we learn more. Please bookmark it to more easily check back for updates.
New Deadline Established: Beneficial Ownership Information (BOI) Reporting
February 25, 2025
The never-ending twists and turns of BOI reporting under the Corporate Transparency Act has yet again provided an update.
Late last week, The Financial Crimes Enforcement Network (FinCEN), a bureau within the U.S. Department of the Treasury, announced that BOI reporting requirements are once again back in effect. Here are the key details from their announcement:
- Based on the February 18 court decision (more information below this update), the Department of the Treasury recognized that reporting companies may need additional time to comply with their BOI reporting obligations. Thus, a 30-day reporting extension followed making March 21, 2025, the new deadline.
- Reporting companies that were previously given a reporting deadline later than the March 21, 2025 deadline must file their initial BOI report by that later deadline. Often, companies effected by natural disasters were granted relief and should follow the deadlines they were given.
- FinCEN also intends to initiate a process this year to revise the BOI reporting rule to reduce burden for lower-risk entities, including many U.S. small businesses.
- Plaintiffs in National Small Business United v. Yellen, No. 5:22-cv01448 (N.D. Ala.)—namely, Isaac Winkles, reporting companies for which Isaac Winkles is the beneficial owner or applicant, the National Small Business Association, and members of the National Small Business Association (as of March 1, 2024)—are not currently required to report their beneficial ownership information to FinCEN at this time.
BOI Reporting is Back (For Now)
February 19, 2024
In the back-and-forth court battle regarding Beneficial Ownership Information (BOI), the Eastern District of Texas has removed its block against the Corporate Transparency Act (CTA) reporting requirements. This February 17 ruling means small business owners once again are required to file their information. However, there are other developments happening with this reporting.
On February 10, the US House of Representatives unanimously voted in favor of pushing the CTA’s reporting deadline to January 1, 2026. It is now with the Senate and is awaiting action. Oral arguments will be heard on April 1 concerning an earlier injunction. As of this posting, the Treasury Department’s Financial Crimes Enforcement Network has not issued any guidance.
What Should You Do?
While this gets sorted out in the courts and in Congress, you can still voluntarily submit your information. Read below to learn more about BOI reporting, find resources about where to report and other frequently asked questions.
BOI Reporting Once Again On Hold
December 27, 2024
A panel with the same Fifth Circuit court has reinstated the injunction blocking reporting for the Beneficial Ownership Information (BOI) that is part of the Corporate Transparency Act (CTA).
Please continue to work with your legal representation to stay apprised of this situation.
We also will continue to update our clients as we receive additional updates.
BOI Reporting Required: Injunction Lifted, Deadline Extended
December 24, 2024
The Corporate Transparency Act (CTA) is now in effect after a recent court ruling. This law requires most businesses to report Beneficial Ownership Information (BOI) to the government. The deadline for some companies to file their initial BOI reports with FinCEN has been extended. This article outlines the new deadlines, explains what information needs to be reported, and provides guidance on how to comply with the CTA.
CTA Deadline Extended After Court Ruling
The Corporate Transparency Act (CTA) is now enforceable after a recent court ruling lifted a previous injunction. This requires businesses to report Beneficial Ownership Information (BOI).
Additionally, after this Monday, December 22 ruling by the Fifth Circuit Court of Appeals, FinCEN, which enforces the CTA, announced that the new filing deadline for most companies is now January 13, 2025.
Please be aware that the case, Texas Top Cop Shop, Inc. v. Garland, is still being litigated but also that the Fifth Circuit stated, “…The government has made a strong showing that it is likely to succeed on the merits in defending CTA’s constitutionality.”
What You Should Do Next
To ensure compliance with the CTA and avoid potential civil and criminal penalties (fines up to $500 per day and imprisonment of up to two years), all business owners must adhere to BOI reporting deadlines:
- Reporting companies created or registered before January 1, 2024: The new deadline for filing initial BOI reports with FinCEN is January 13, 2025.
- Reporting companies created or registered in the U.S. on or after September 4, 2024, that had a filing deadline between December 3, 2024, and December 23, 2024: The new deadline for filing initial BOI reports with FinCEN is January 13, 2025..
- Reporting companies created or registered in the U.S. on or after December 3, 2024, and before December 23, 2024: Have an additional 21 days from their original filing deadline to file initial BOI reports with FinCEN.
- Reporting companies created or registered on or after January 1, 2025: Have 30 days to file initial BOI reports with FinCEN after receiving actual or public notice that their creation or registration is effective.
- Reporting companies that qualify for disaster relief may have extended deadlines beyond January 13, 2025. These companies should abide by whichever deadline falls later.
Where Do Businesses Report and File Their BOI?
To report your company’s BOI information and for additional information, please go to the Financial Crimes Enforcement Network’s (FinCEN) website.
Brady Ware encourages all business owners to work with their corporate legal counsel to help handle reporting.
Quick Takeaways: Corporate Transparency Act
- The CTA is Again Enforceable: A recent court ruling lifted the injunction that had previously blocked the implementation of the CTA. This means businesses must now comply with the law’s requirements.
- New Filing Deadline for BOI Reports: The deadline for most companies to file their initial Beneficial Ownership Information (BOI) reports with the Financial Crimes Enforcement Network (FinCEN) MIGHT be pushed to January 1, 2026. See full article for complete details.
- Businesses Must Comply: Failure to comply with the CTA can result in significant penalties, including civil and criminal fines, and even imprisonment.
Questions?
Adam manages a variety of tax and accounting engagements for business clients in numerous industries, including manufacturing, real estate, construction, alternative investments, and professional services. He has experience in federal tax, multi-state corporate income and franchise tax, and municipal income tax. In addition to his tax compliance background, Adam specializes in preparing and managing complex partnership engagements.
Related Articles:
BOI Reporting: Another Court Ruling Halts Implementation – January 10
BOI Reporting and Ongoing Updates – December 16, 2024
BOI Latest Court Rulings – December 5, 2024
Deadline Looming: Beneficial Ownership Information (BOI) – November 19, 2024
Corporate Transparency Act: What Businesses are Affected? – January 2, 2024
Corporate Transparency Act: Revised BOI Reporting Rules – January 3, 2024