12-24-24 FINCEN EXTENDS CORPORATE TRANSPARENCY ACT (“CTA”) FILING DEADLINES
FINCEN EXTENDS CORPORATE TRANSPARENCY ACT (“CTA”) FILING DEADLINES
As a result of the 12/23/24 ruling by the Fifth Circuit Court of Appeals reinstating the CTA’s requirements, reporting companies are required to file beneficial owner information reports (“BOIRs”) with FinCEN. However, in light of the ruling, FinCEN has extended the initial filing deadlines as follows:
Reporting Company |
Original Deadline to File Initial BOIR |
Extended Deadline to File Initial BOIR |
Formed (or registered if foreign) prior to January 1, 2024 |
January 1, 2025 |
January 13, 2025 |
Formed (or registered if foreign) on or after September 4, 2024 |
Between December 3, 2024 and December 23, 2024 |
January 13, 2025 |
Formed (or registered if foreign) on or after December 3, 2024 and on or before December 23, 2024 |
The last date which is within 90 days of formation (or registration if foreign) |
The date which is 21 days from the original deadline |
Reporting companies that qualify for disaster relief may have extended deadlines that fall beyond January 13, 2025.
Reporting companies formed or registered on or after January 1, 2025 still have only 30 days to file their initial BOIRs with FinCEN. Once an initial BOIR has been filed, any change in the reported information requires the filing of an updated BOIR within 30 days of the change.
You can read FinCEN’s press release granting the extensions here: https://www.fincen.gov/boi (see “Alert: Updates to Beneficial Owner Information Reporting Deadlines – Beneficial Ownership Information Reporting Requirements Now in Effect, with Deadline Extensions”).
We are prepared to help your company navigate the CTA’s reporting requirements. If you have any questions, please reach out to Kate Polozie, Esq. at (585) 987-2910 or kpolozie@woodsoviatt.com, Danielle Ridgely, Esq. at (585) 987-2914 or dridgely@woodsoviatt.com, or another member of the Business and Tax Department at Woods Oviatt Gilman LLP.
