The Corporate Transparency Act (CTA), which went into effect on January 1, 2024, mandates that almost all LLC owners submit annual beneficial ownership reports (BOI) to the Financial Crimes Enforcement Network (FinCEN). On December 3, 2024, the U.S. District Court for the Eastern District of Texas issued a preliminary injunction barring enforcement of the CTA nationwide.
However, on December 23, 2024, a three-judge panel of the Fifth Circuit stayed the lower court’s injunction, thereby reinstating the reporting obligations required under the CTA.
In response to the ruling, FinCEN announced an extension of the compliance deadlines, as follows, including:
- Reporting companies created or registered prior to January 1, 2024, which originally had a filing deadline of January 1, 2025, now have until January 13, 2025 to file their BOI reports.
- Reporting companies created or registered on or after September 4, 2024, which had a filing deadline between December 3, 2024, and December 23, 2024, now have until January 13, 2025 to file.
- Reporting companies created or registered on or after December 3, 2024, and on or before December 23, 2024, now have an additional 21 days from their original filing deadline to file.
