BOI Reporting - Update

Over the past few weeks, you've probably heard a lot about the Beneficial Owners Information Reporting, which is required under the Corporate Transparency Act. In November we sent a letter to our clients regarding this. The deadline to file iss January 1, 2025 with a penalty of $590.00 per day if a company fails to file.

Please note the BOI reporting requirement applies to small business, with some exceptions.

There has been a last-minute development with regards to the Corporate Transparency Act or CTA. On December 3rd, 2024, late afternoon, a federal District Court in Texas, issued an injunction that prevents the enforcement of the January 1, 2025 deadline. The DOJ has yet to respond to this injunction. What we know right now is that the January 1, 2025 deadline is not enforceable, due to the injunction. Currently there is no further information on this. You are still required to file. 

However, the future of the enforcement of the CTA is uncertain. As we get more updates we will publish them. The AICPA has issued a statement that acknowledged the potential effects of the injunction and urged CPAs assisting clients with BOI reporting to be prepared. Below is that statement:

“Under the injunction, FinCEN is barred from enforcing BOI filing requirements while the case is pending,” the statement said. “Best practices dictate that at a minimum, those assisting clients with BOI report filings gather the required information from the clients and are prepared to file the BOI report if the injunction is lifted. While it is unlikely that the injunction will be lifted prior to the final outcome of the proceedings, we advise being prepared in the event that there is a reversal.”

We are offering to file the BOI reports for existing clients if you so choose to file this report.