The Fifth Circuit has removed the nationwide injunction concerning Corporate Transparency Act reporting. The Fifth Circuit’s decision overrides the earlier nationwide relief granted by the district court.
Litigation will continue in this matter, but, as of now, the CTA/BOI reporting requirements are active and enforceable. However, FinCEN has granted certain extensions to the reporting deadlines. See the Alert on the FinCEN website for full details.
Action Items:
- Ensure compliance by filing BOIRs for all entities formed prior to January 1, 2024, by the January 13, 2025 extended deadline (the deadline was previously January 1, 2025).
- Address any BOIR reports that were due while the injunction was in place. Entities formed in 2024 were to file within 90 days of formation. However, FinCEN has granted some extensions for entities formed between September 4, 2024 – December 23, 2024.
- Continue to monitor the FinCEN website for any updates or relief that may apply.
We understand the timing of this news, especially during the holiday season, is far from ideal. Nonetheless, we encourage you to focus on completing these reporting requirements to avoid any non-compliance issues.
