Insights

5th Circuit Says BOI Back On

December 24, 2024

Written by James Sanders

On December 23rd, the 5th Circuit said “Hold My Beer” to the Eastern District of Texas and lifted the nationwide injunction on BOI reporting. Nothing like a last minute Christmas gift for business owners. As a result of this ruling, FinCen issued the following updates:
• Reporting companies created or registered before Jan. 1, 2024, have until Jan. 13, 2025, to file initial BOI reports with FinCEN. (versus the prior requirement of Jan. 1, 2025.)
• Reporting companies created or registered in the United States on or after Sept. 4, 2024, that had a filing deadline between Dec. 3, 2024, and Dec. 23, 2024, have until Jan. 13, 2025, to file initial BOI reports with FinCEN.
• Reporting companies created or registered in the United States on or after Dec. 3, 2024, and on or before Dec. 23, 2024, have an additional 21 days from their original filing deadline to file initial BOI reports with FinCEN.
• Reporting companies that qualify for disaster relief may have extended deadlines that fall beyond Jan. 13, 2025. These companies should abide by whichever deadline falls later.
• Reporting companies that are created or registered in the United States on or after Jan. 1, 2025, have 30 days to file initial BOI reports with FinCEN after receiving actual or public notice that their creation or registration is effective.

About the Author

James Sanders

James Sanders

Managing Partner

James Sanders is an experienced attorney with a deep and comprehensive knowledge of business law, specializing in mergers and acquisitions. Combining extensive legal expertise with a strong foundation in business strategy, James provides sophisticated and practical counsel tailored to the complex needs of business owners and corporate clients.

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