California CPA January/February 2025 | Page 8

BOI : Nationwide Injunction Lifted ; Filing Deadlines Reinstated
On Dec . 3 , a federal court issued a preliminary nationwide injunction that temporarily halted enforcement of the Corporate Transparency Act ( CTA ) and its beneficial ownership information ( BOI ) reporting requirements . During that injunction , the Financial Crimes Enforcement Network ( FinCEN ) could not enforce BOI filing requirements while the lawsuit was ongoing .
On Dec . 23 , 2024 , the Fifth Circuit Court of Appeals stayed that injunction , meaning it is no longer in effect and FinCEN may once again enforce the CTA and its BOI requirements — including coming reporting deadlines .
However , for those with an initial deadline of Jan . 1 , 2025 , FinCEN has extended the deadline to Jan . 13 , 2025 . Additional details for the extended deadline include :
• For Companies Created or Registered Prior to Jan . 1 , 2024 : These companies now have until Jan . 13 , 2025 , to file their initial BOI reports with FinCEN ( extended from the original Jan . 1 , 2025 , deadline ).
• For Companies Created or Registered on or after Sept .
4 , 2024 : If the original filing deadline fell between Dec . 3 , 2024 – Dec . 23 , 2024 , these companies now have until Jan . 13 , 2025 , to file . If created or registered between Dec . 3 , 2024 – Dec . 23 , 2024 , these companies have an additional 21 days from their original filing deadline to submit their reports .
• For Companies Qualifying for Disaster Relief : These companies may have extended deadlines beyond Jan . 13 , 2025 , and should adhere to whichever deadline falls later .
• For Companies Created or Registered on or After Jan . 1 , 2025 : These companies must file their initial BOI reports with FinCEN within 30 days of receiving actual or public notice that their creation or registration is effective . For further information and resources , please visit the
AICPA ’ s BOI Resource Center .
CalCPA has been collaborating with the AICPA and various stakeholders to request a deadline extension and will continue to work with stakeholders for a delay and additional reporting guidance for affected entities and the CPAs advising them .
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