The ongoing developments around the FinCEN Beneficial Ownership Information (BOI) filing requirements have left many entities wondering about their next steps. With the latest news putting the requirement to file BOI reports on hold once again, we want to provide clarity on the timeline of events and offer guidance to help make informed decisions.
A Brief Timeline of Events
- March 24, 2023: FinCEN announces the new BOI filing requirements. Reporting entities registered with a Secretary of State or equivalent office before January 1, 2024, are required to file their BOI reports by January 1, 2025.
- December 3, 2024: A U.S. District Court in Texas issues a nationwide injunction, temporarily halting the BOI filing requirements.
- December 23, 2024: The Fifth Circuit Court of Appeals lifts the District Court’s injunction, reinstating the BOI filing requirements. To accommodate the reinstatement, FinCEN extends the filing deadline from January 1, 2025, to January 13, 2025.
- December 27, 2024: The Fifth Circuit Court of Appeals reinstates the lower court’s injunction, once again placing a temporary hold on the BOI filing requirements. As a result, the January 13, 2025, filing deadline has been suspended.
Current Status
As of now, the requirement to file BOI reports is on hold. However, it is essential to remain proactive in light of the legal back-and-forth, as the filing requirement may be reinstated with a short compliance window.
Recommendations for Clients
While the BOI filing requirement is currently paused, we recommend the following approaches based on your situation:
- For those who have already started the filing process: We encourage you to complete the steps and submit the filing, even during the current hold. This ensures compliance without any last-minute rush if the requirement is reinstated.
- For those who have not yet begun the filing process: We suggest starting now and working toward completion. Taking early action reduces the risk of time constraints if and when the filing deadline is reinstated.
Our priority is to keep you informed so you can make the best decision for your business. While some activists have called for a one-year postponement of the filing deadline, these efforts have not gained significant traction. Preparing in advance remains the most prudent course of action.
How We Can Help
If you need assistance with your BOI filing or have questions about how these developments may affect your reporting obligations, our team is here to help. Please reach out to us for personalized guidance and support at spteam@gpw.cpa.
We will continue to monitor the situation and provide updates as new information becomes available.
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