TEL: (410) 879-3331
Current Status & Court Case Updates
December 27, 2024
Deadline Stay - Voluntary Submission Only - Again
On Thursday, December 26th, a federal court of appeals reinstated the injunction that blocks the BOIR requirement; however, the court is still considering the appeal that was filed December 5th.
Currently, reporting companies are not required to file beneficial ownership information with FinCEN and are not subject to liability if they fail to do so while the injunction remains. Voluntary submissions of reports are still being accepted.
We are continuing to follow this court case closely for future updates.
The most recent publication containing the above information can be found on NFIB’s website here:
Press Release
Legal Blog Post
For further information on the BOIR, please visit FinCEN’s website.
December 24, 2024
BOIR Requirements Back in Effect with Deadline Extensions
On Monday, December 23rd, per the Federal Court of Appeals decision, “…reporting companies, except as indicated below, are once again required to file beneficial ownership information with FinCEN. However, because the Department of the Treasury recognizes that reporting companies may need additional time to comply given the period when the preliminary injunction had been in effect, we have extended the reporting deadline…”.
The updated reporting deadlines are as follows:
-
Companies created/registered prior to January 1, 2024
-
January 13, 2025
-
-
Companies created/registered on or after September 4, 2024
-
January 13, 2025
-
-
Companies created/registered on or after December 3, 2024, and on or before December 23, 2024
-
90 days after creation + additional 21 days
-
-
Companies that are created/registered on or after January 1, 2025
-
30 days to file after receiving actual or public notice that their creation or registration is effective
-
Per the current ongoing court cases, the only persons/entities not required to report their beneficial ownership information to FinCEN are, “…Isaac Winkles, reporting companies for which Isaac Winkles is the beneficial owner or applicant, the National Small Business Association, and members of the National Small Business Association (as of March 1, 2024)”.
December 9, 2024
Deadline Stay - Voluntary Submission Only
On Tuesday, December 3rd, per a federal court order, “…reporting companies are not currently required to file beneficial ownership information with FinCEN and are not subject to liability if they fail to do so while the order remains in force. However, reporting companies may continue to voluntarily submit beneficial ownership information reports.”
Please be advised that a Notice of Appeal was filed on December 5, 2024. We are currently following this case and FinCEN’s website closely for any updates.
At this time, our office will need confirmation if you wish for us to proceed with filing the initial information report for you.
For further information, please visit FinCEN’s website.
Corporate Transparency Act (CTA) and
Beneficial Ownership Information Report (BOIR)
BOIR Final Notice
Emailed to business clients on November 26, 2024.
BOIR Update Notice
Emailed to business clients on September 1, 2024.
Corporate Transparency Act Notice
Emailed to all clients on January 29, 2024.
If you would like David C. Bryant, CPA to file the initial report for you, please email fincen@davidcbryantcpa.com for us to prepare a separate engagement letter.
Due to the sensitive and legal nature of the CTA, including the BOIR, assisting you with your compliance is not within the scope of our current engagement on file. If you choose to engage us for such services, including any advice, assistance, or answers to questions in relation to the BOIR, you will be required to sign a separate engagement letter.
Without signing the separate engagement letter, you have sole responsibility for your compliance with the CTA, including its BOI reporting requirements and the collection of relevant ownership information.
Please refer to the links below for step-by-step filing instructions and frequently asked questions.
Help & Resources:
Frequently Asked Questions: