Vermont Society of Certified Public Accountants
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Update on BOI delay and Continuing Resolution--UPDATED 8.30 PM
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Dec 23, 2024 —
The 5th Circuit Court of Appeals has reversed its previous rejection of FinCEN's appeal of the BOI injunction. This decision effectively lifts the injunction. However, for those with an initial deadline of January 1, 2025, the deadline has now been extended to January 13, 2025.
- For companies created or registered prior to January 1, 2024:
These companies now have until January 13, 2025, to file their BOI reports with FinCEN (extended from original January 1, 2025, deadline).
- For companies created or registered on or after September 4, 2024:
If the original filing deadline fell between December 3, 2024, and December 23, 2024, these companies now have until January 13, 2025, to file.
If created or registered between December 3, 2024, and December 23, 2024, these companies have an additional 21 days from their original filing deadline to submit reports.
- For companies qualifying for disaster relief:
These companies may have extended deadlines beyond January 13, 2025, and should adhere to whichever deadline falls later.
- For companies created or registered on or after January 1, 2025:
These companies must file their initial BOI requests with FinCEN within 30 days of receiving actual public notice that their creation or registration is effective.
AICPA continues to advocate for a full year delay, but until further notice the filing deadlines above remain in place. Check their BOI Resource Center for continuing updates.
Previously reported: Congress passed a Continuing Resolution to avert a government shutdown. The package includes:
- Adjustments to the farm bill provisions
- The exclusion of any debt limit increase language.
The CR does NOT include the one-year Beneficial Ownership Information (BOI) reporting delay.