On December 23, 2024, the United States Court of Appeals for the Fifth Circuit lifted the nationwide preliminary injunction on enforcement of the Corporate Transparency Act (CTA), which had been issued by the United States District Court for the Eastern District of Texas on December 3, 2024. This means that the CTA BOI reporting requirements and deadlines are back in effect.
FinCEN has extended the BOI Reporting deadlines. Reporting companies that were created or registered prior to January 1, 2024 have until January 13, 2025 to file their initial beneficial ownership information reports with FinCEN. (These companies would otherwise have been required to report by January 1, 2025.) If you’re effected and have yet filed your BOI do so now to avoid additional penalties.
Reporting companies created or registered in the United States on or after September 4, 2024 that had a filing deadline between December 3, 2024 and December 23, 2024 have until January 13, 2025 to file their initial beneficial ownership information reports with FinCEN. Again, if you have not yet done so, make the reporting your immediate top priority.
Reporting companies created or registered in the United States 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 initial beneficial ownership information reports with FinCEN.
Reporting companies that qualify for disaster relief may have extended deadlines that fall beyond January 13, 2025. These companies should abide by whichever deadline falls later.
Reporting companies that are created or registered in the United States on or after January 1, 2025 have 30 days to file their initial beneficial ownership information reports with FinCEN after receiving actual or public notice that their creation or registration is in effect.
If you are unsure whether the law applies to you or what deadline applies to your business, contact your business attorney.
The information presented is not intended to be, and does not constitute, “legal advice.” Because each situation varies, and only brief summary information is provided here, you should not use this information as a basis for action unless you have independently verified with your own counsel that it applies to your particular situation.
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