BlogLine

Inching closer to a BOI reporting requirement – a potential 30-day extension

2/10/25

By: William R. Covino and Nancy M. Reimer

A new deadline to file beneficial ownership reports (“BOI Reports”) may be imposed soon. As our prior client updates have reported, approximately 32.6 million business entities have been trying to predict whether the Financial Crimes Enforcement Network (“FinCen”) will be able to mandate companies file BOI Reports under the Corporate Transparency Act (“CTA”) or if any of the previously issued nationwide injunctions will become permanent. These injunctions were issued by the Eastern District of Texas in Texas Top Cop Shop, Inc. et al. v. Merrick Garland, Attorney General of the United States, et al., Civil Action No. 4:24-CV-478 (“Texas Top Cop Shop”) and Samantha Smith and Roberts Means v. U.S. Department Treasury, No. 6:24-CV-336 (“Samantha Smith”). 

Given the Supreme Court of the United States recently stayed the Texas Top Cop Shop nationwide injunction, the government sought to strike while the iron was hot by attempting to stay the Samantha Smith nationwide injunction. If this occurs, FinCen will reportedly extend the deadline to file BOI Reports by thirty days to minimize the burden on reporting companies.

With the CTA and reporting requirement likely returning soon, reporting companies and tax practitioners should not remain idle while they await a decision on whether a new deadline should be imposed. Reporting entities should continue to compile the necessary information to file BOI Reports in advance of any future deadline set by FinCen. We will continue to follow and report developments concerning the CTA and its reporting requirements to you. 

For more information on this topic, please contact Nancy Reimer at nancy.reimer@fmglaw.com; Will Covino at william.covino@fmglaw.com; or your local FMG relationship partner.