With only days left in 2024, the Fifth Circuit Court of Appeals has reversed the Texas federal court’s nationwide injunction against enforcement of the Corporate Transparency Act (CTA). This means, the CTA reporting requirements are now back in effect though the deadlines have been pushed back slightly—in most cases to January 13, 2025. We expect there to be further activity on the question of CTA’s enforceability before it is finally resolved. The plaintiffs in the case are likely to appeal this new ruling, either to the entire Fifth Circuit or to the U.S. Supreme Court. The outcome of either of those options is uncertain.
The new deadlines communicated by the Treasury Department’s FinCEN are as follows:
- Reporting companies created prior to January 1, 2024, have until January 13, 2025, to file their beneficial ownership information (BOI) reports.
- Reporting companies created on or after September 4, 2024, that had a filing deadline between December 3, 2024, and December 24, 2024, have until January 13, 2025, to file their BOI reports.
- Reporting companies created on or after December 3, 2024, and on or before December 23, 2024, have an additional 21 days from their original filing deadline to file their BOI reports.
The full FinCEN alert is included below and can also be found online here.
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