Oh BOI

Beneficial Ownership Information alert. From Proskauer:

“On December 23, 2024, the Fifth Circuit of the United States Court of Appeals (the “Fifth Circuit”) issued an order that has the effect of reinstituting the deadlines under the Corporate Transparency Act (the (“CTA”)….

“The CTA requires a range of entities, primarily smaller, otherwise unregulated companies, to file a report with the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) identifying the entities’ beneficial owners—the persons who ultimately own or control the company—and provide similar identifying information about the persons who formed the entity.

“FinCEN has recognized that the timing of the order lifting the injunction may be particularly burdensome and has extended the reporting deadlines.  Accordingly, reporting companies created prior to January 1, 2024, that are not eligible for an exemption, are required to file beneficial ownership reports by January 13, 2025 (and not January 1, 2025).”