Corporate Transparency Act Deadline Reinstated

The U.S. Court of Appeals for the Fifth Circuit has reinstated the Beneficial Ownership Information (BOI) reporting requirements under the Corporate Transparency Act (CTA). While the original January 1, 2025, deadline was temporarily delayed by a preliminary injunction, the Financial Crimes Enforcement Network (FinCEN) extended the compliance deadline to January 13, 2025.

AAFCPAs advises that clients take immediate steps to meet this deadline. Reporting companies must file BOI reports with FinCEN by January 13, 2025, to avoid penalties for noncompliance.

To prepare, clients should:

• Gather required information, including the names, addresses, dates of birth, and identification numbers of all beneficial owners. A beneficial owner is an individual or entity that ultimately owns or controls a company, even if they are not listed as the official owner.
• Verify the accuracy of this information to prevent delays or errors during submission.

FinCEN also provided updated deadlines for specific circumstances:

• Companies created or registered before January 1, 2024, must file by January 13, 2025.
• Companies formed between December 3 and December 23, 2024, have an additional 21 days from their original filing deadline.
• Companies qualifying for disaster relief may have further extensions.
• Entities created or registered on or after January 1, 2025, must file within 30 days of their formation.

AAFCPAs is monitoring these developments and will provide updates and resources as appropriate to assist clients in navigating these requirements. If you have questions, please contact Erica Nadeau, CPA, MST, Tax Partner at 774.512.4111 or enadeau@aafcpa.com—or your AAFCPAs Partner.