As a client or former client of this law firm, we are again reaching out to you regarding the federal filing requirements under the Corporate Transparency Act (CTA) and the regulations promulgated under the CTA by the U.S. Treasury Department. The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) has required that individuals who have control or an ownership interest in a corporation or LLC exceeding 25% must file as a “beneficial owner” (referred to as BOI).
FinCEN’s filing requirement has been subject to several pending legal challenges that have affected the reporting deadlines. The most recent court decision has come from the U.S. District Court for the Eastern District of Texas. As of February 18, 2025, BOI reporting requirements under the CTA are once again back in effect. The new deadlineto file an initial, updated and/or corrected BOI report is now March 21, 2025.
Please be aware that this deadline may be subject to change as FinCEN will spend the next few weeks assessing its options to further modify the deadlines.
The filing requirement can be accomplished either by (1) downloading the FinCEN form and filing a completed PDF version of the form, or (2) completing the form online at: https://boiefiling.fincen.gov/fileboir. Do not hesitate to contact us with any questions and note that we can assist you with this requirement by filing the form on your behalf and ensuring its appropriate and timely submission. If you elect to engage our services in completing the reporting, we will send you an engagement letter to confirm the scope of our work and the fees associated.
As with past developments, Black & Wadhams will keep you updated as to the status of the reporting requirement and whether you will be required to report by the March 21, 2025, deadline, or in the future.
