The Financial Crimes Enforcement Network (FinCEN) announced a significant relief measure under the Corporate Transparency Act (CTA) for businesses affected by five hurricanes impacting the U.S. in 2024. Hurricane relief extends the deadline for submitting a Beneficial Ownership Information Report (BOIR) by six months for companies that meet specific criteria. Please visit this link for Part 1 and this link for Part 2 in this series.
Which Companies Qualify for the Extension?
To qualify for this extension, a reporting company must meet two key requirements:
- Deadline Timing: The reporting company’s original deadline for filing an initial or updated BOIR must fall between the dates designated by FinCEN for the applicable hurricane.
- Location: The company’s principal place of business must be in an area designated by both the Federal Emergency Management Agency (FEMA) for individual or public assistance and the Internal Revenue Service (IRS) for tax filing relief as a result of a disaster caused by the applicable hurricane (in the case of Hurricanes Debby and Helene, this includes disasters caused by the related tropical storm).
The deadline timelines for relief are:
- Hurricane Beryl: July 4, 2024 to October 2, 2024
- Hurricane Debby: July 31, 2024 to October 29, 2024
- Hurricane Francine: September 8, 2024 to December 7, 2024
- Hurricane Helene: September 22, 2024 to December 21, 2024
- Hurricane Milton: October 4, 2024 to January 2, 2025
If additional areas are designated for tax relief by the IRS after the date of FinCEN’s announcement (October 29, 2024), companies in those areas will automatically receive the same six-month extension to submit their BOIR.
Consider a company created on July 25, 2024, that was impacted by Hurricane Helene. Normally, its initial BOIR would be due by October 23, 2024. However, if this company is located in a qualifying disaster area, its new reporting deadline will be April 23, 2025.
Assistance for Companies Outside Disaster Areas
FinCEN is also offering support to companies whose principal place of business is outside the affected areas but need to access records located within the disaster zones to meet their filing obligations. These companies should contact FinCEN for assistance.
Reporting Early
Although FinCEN provided deadline extensions under the circumstances discussed above, PilieroMazza strongly recommends that all entities—to the extent required to file—do not delay filing its BOIR unless necessary.
PilieroMazza attorneys are here to assist you. If you need guidance concerning compliance with the CTA, please contact Meghan Leemon, Abby Baker, Cole Fox, or another member of the Firm’s Government Contracts or Business & Transactions practice groups.
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