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Seriously? BOI Filing Requirements Paused Again!

12/28/2024

The ongoing legal back-and-forth over Beneficial Ownership Information (BOI) filing requirements under the Corporate Transparency Act (CTA) has left many business owners—including those in the construction industry—feeling uncertain about what to do next. We share your frustration.

The CTA was introduced to combat money laundering and increase financial transparency, requiring most businesses to disclose key ownership information. But recent developments have thrown the timeline and requirements into disarray.

Timeline of Events

  • January 1, 2021: The CTA established BOI filing requirements, with a filing deadline originally set for January 1, 2025.
  • December 3, 2024: A federal court issued an injunction, pausing the enforcement of BOI requirements.
  • December 26, 2024: The Fifth Circuit Court of Appeals reversed the injunction, reinstating the BOI filing mandate and moving the deadline to January 13, 2025.
  • December 27, 2024: The injunction was reinstated, once again halting BOI enforcement.


What Does This Mean for Construction Companies?

The constant changes are creating a frustrating and unpredictable environment for compliance. Although filings are not currently required, the rules could be reinstated at any time, lilely with little notice and limited time to act.

For construction company owners, which often have complex ownership structures, this uncertainty adds an extra layer of administrative burden and risk. Missing a sudden deadline could lead to hefty penalties, including fines and potential criminal charges.

How Should You Prepare?

Rather than waiting for the next ruling or deadline, we recommend preparing and filing your BOI report now. Taking proactive steps can help you avoid scrambling under pressure if the filing requirements return.

How to File

We are not offering BOI filing as a service at Ceschini CPAs, but we did create instructions for you to follow. in most cases, it is relatively easy to file yourself. If you do want assistance, reach out to us, and we can recommend reputable providers to help you.