BOI Reporting Is Back: What You Need to Know (LLC)
If you’ve been keeping an eye on your LLC filings, here’s an important update: the beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act (CTA) are back in effect. After a period of legal back-and-forth, FinCEN has announced that most companies now have until March 21, 2025 to file a new, updated, or corrected BOI report.
What Happened?
For a while, many of us were relieved to hear there was no immediate need to file a BOI report. That changed following a federal district court decision in the Eastern District of Texas. Previously, an order in the case of Smith et al. v. U.S. Department of the Treasury et al. had halted enforcement of the BOI reporting requirements. However, that pause was only temporary.
On February 19, FinCEN confirmed that the reporting rules are now in force, with the primary deadline set for March 21, 2025. (Note that if your company qualifies for a later deadline—such as those provided by disaster relief extensions—that later date will apply.)
Meanwhile, ongoing litigation and proposed legislation may influence future deadlines or requirements, so it’s wise to keep an eye on further developments.
Why the Pause and Why It’s Back Now
The back-and-forth was confusing, but here’s the simplified version:
- Pause: Initially, a federal court in Texas issued an injunction that temporarily halted the BOI reporting requirement. This meant that for a while, you didn’t need to worry about filing.
- Reinstatement: A subsequent stay of that injunction pending appeal meant that the reporting requirements could resume, and FinCEN has now confirmed this by setting a firm filing deadline.
This legal back-and-forth shows that while the process may seem complicated, the BOI reporting requirements are both legitimate and enforceable.
How to File Your BOI Report
If you’re ready to get your report filed, here are a few straightforward steps to follow:
- Determine Your Filing Requirement:
Confirm whether your LLC is classified as a “reporting company” under the CTA. Generally, if your LLC isn’t exempt (for instance, many larger or publicly traded companies might be), you’ll need to file. - Gather Your Information:
You’ll need details on the beneficial owners of your company—typically including names, addresses, and other identifying information. - Complete the BOI Report:
Access FinCEN’s online portal and follow the instructions to complete your report. Be sure to review your data carefully for accuracy. For filing and keeping up with changes in information, check out the official website: https://www.fincen.gov/boi - Submit Before the Deadline:
Ensure your report is filed by March 21, 2025—or by your applicable later deadline if one has been granted due to specific circumstances.
Need Assistance?
These new requirements can be challenging, but they typically only require a one-time filing—as long as your beneficial ownership information doesn’t change. If you’d prefer help or a personalized walkthrough, I’m available on Zoom. We can set up a call to file your BOI report together, just as we do for LLC creation or renewal. Read some of my clients’ reviews to decide if you want my support.
I look forward to your questions!
Paul Trausner
Lived on 4 continents and visited 60+ countries
Specializes in expat consultation for Latin America,
including residency coaching, US LLC formation, and tax optimization strategies
Disclaimer:
This article provides general information about the BOI reporting requirements under the CTA. It is not legal advice. For advice tailored to your specific situation, please consult with an attorney.
Stay informed and take action early to ensure your LLC remains compliant. Feel free to reach out if you have any questions or need further assistance!
