Important Corporate Transparency Act Update – Injunction Lifted

CTA Overview

We wanted to provide you with recent updates on the Corporate Transparency Act (“CTA”).  Under the CTA, FinCEN (the “Financial Crimes Enforcement Network of the U.S. Treasury”) is required to develop a nationwide database of private company “beneficial owners”. The CTA requires every company in the U.S. to file beneficial ownership information (BOI) reports with FinCEN.

 
Recent Update

As we last reported, a Federal District Court in Texas had issued a nationwide preliminary injunction against the CTA finding that the CTA and the Reporting Rule likely violates constitutional protections. Unfortunately, on December 23, 2024, the Fifth Circuit Court of Appeals issued a stay and lifted the injunction. 

 

What Does this Mean for You?

This means that small business owners once again have to comply with the CTA at this time. However, the Department of Treasury has granted an extension for filing initial BOI reports as further outlined below.

Date of Company Formation

Filing Deadline

Companies formed prior to January 1, 2024

January 13, 2025

Companies formed on or after September 4, 2024

January 13, 2025

Companies formed between December 4, 2024 and December 23, 2024

Normal 90 day window extended by 21 days

 

What Should I Do?

If your company meets the requirements under the CTA, you must file your initial BOI report. Please let us know immediately if you need our assistance with preparing and filing the BOI report. 

The situation is subject to change and we will keep you updated as new developments occur.

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