BOI Reporting Deadline Reinstated – Now Due by March 21, 2025
This Monday, February 17, 2025, the Eastern District of Court of Texas lifted the injunction for filing the BOI report.
The Corporate Transparency Act (CTA) P.L. 116-283 and its requirements for filing the Beneficial Ownership Information (BOI) report with the Financial Crimes Enforcement Network (FinCEN) has been reinstated.
Accordingly, all reporting companies are once again obligated to file their BOI with FinCEN.
The new filing deadline is now MARCH 21,2025.
The rules are as follows:
Companies created or registered before January 1, 2024 must file their initial BOI by March 21, 2025.
Companies created or registered in 2024 must file within 90 days of receiving actual notice of their creation or registration. Due to the ongoing legal disputes, they also have until March 21, 2025.
Companies created or registered on or after January 1, 2025 must file within 30 days of creation or registration.
Reporting companies include all domestic corporations, limited liability companies, or similar entities created by any filing with a secretary of state (or equivalent), and any foreign entities registered to do business in the United States, unless exempt.
There are 23 exemptions and include large operating companies (more than 20 full-time employees, over $5 million in U.S. receipts, and a physical U.S. office), certain regulated entities such as banks, SEC- registered companies and wholly owned subsidiaries of exempt entities.
The following information must be reported on the BOI report:
Full legal name
Date of Birth
Residential address (or business address for applicants acting in a professional capacity)
A valid form of identification such as a driver’s license, a non-expired U. S. passport, or some form of issued state ID.
Businesses should gather the necessary information to file the BOI by the March 21, 2025 deadline.
Non-compliance can result in civil penalties of up to $500 per day and criminal penalties (fines up to $10,000 and/or imprisonment).
Please note that there are pending legal challenges and proposed legislation in Congress. Moreover, the US Supreme Court will ultimately rule on the CTA law and its constitutionality.
For further guidance and assistance please contact either Donald B. Tipping at email: don@tippingtax.com, or Emilia K. Voge-Tipping at email: em@tippingtax.com, or our office manager, Ms. Kim Blevins at email cs1@tippingtax.com. We would be happy to prepare your BOI filings to comply with the March 21, 2025 deadline for a fee of $200.
