February 28, 2025

If you have been tracking the movement of the Beneficial Ownership Information Reporting and Corporate Transparency Act as it makes its way through our Federal Court system you will not be surprised to learn that yet another ruling has been released on this matter today.

How does today’s ruling affect you?

The short answer is that your company(ies) DO need to file a BOIR to be compliant with the CTA unless they qualify under one of the exceptions under the law. Currently, the injunction against the CTA is not in effect until the Court of Appeals issues an opinion.

In the meantime, FinCEN extended the BOIR filing deadline to March 21st. This update indicates that while a new deadline has been issued, fines or penalties will not be imposed nor will enforcement actions be taken against any companies based on a failure to file a BOIR until they publish an interim rule. That new rule is expected to be issued on or before March 21st.

While there’s still some uncertainty surrounding this Act, failure to comply could create significant risk to your business (penalties for non-compliance are steep at $500 per day per beneficial owner and possible jail time.)

Even though you may have heard that you did not need to file a BOIR during one of the “off again” moments, we are advising our clients to comply with the Act. If you would like assistance with filing your BOIR or other business and corporate related matters, please contact your attorney or Kim, Lahey & Killough attorney Emily Bohan or Tony Nolte.

Please note that Kim, Lahey & Killough will not file a BOI report for you, nor arrange to have a BOI report filed for you unless you reach out to us directly to request assistance.
For more information, please visit https://kimandlahey.com/practice-areas/corporate-transparency-act/