We want to inform you about recent developments regarding Beneficial Ownership Information (BOI) reporting under the Corporate Transparency Act (CTA).
On December 3, 2024, a federal district court ruled the Corporate Transparency Act (CTA) likely unconstitutional and temporarily prohibited enforcement of its BOI reporting rule. As a result, the Financial Crimes Enforcement Network (FinCEN) was barred from enforcing BOI filing requirements.
Recent Developments:
December 5, 2024: The Department of Justice (DOJ) filed an appeal against the ruling.
December 13, 2024: The Attorney General submitted an emergency motion to stay the injunction.
December 23, 2024: The Fifth Circuit Court lifted the injunction, reinstating FinCEN’s authority to enforce BOI reporting requirements.
Updated BOI Reporting Deadlines:
FinCEN has extended or adjusted reporting deadlines to account for the temporary pause in enforcement:
Entities Created Before January 1, 2024:
Deadline extended to January 13, 2025.
Entities Created Between September 4, 2024, and December 23, 2024:
Deadline extended to January 13, 2025.
Entities Created Between December 3, 2024, and December 23, 2024:
Additional 21 days from their original deadline.
Entities Created On or After January 1, 2025:
Must file within 30 days of receiving notice.
Additional Considerations:
Entities qualifying for disaster relief may be eligible for extended deadlines or delays. Please contact us for guidance if you believe this may apply to your business.
We strongly encourage all affected entities to review their BOI reporting obligations and take necessary steps to ensure compliance. Our team is available to assist you with filing requirements or address any questions you may have regarding these changes.
Thank you for your attention to this important update.
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