A significant update regarding the Corporate Transparency Act (CTA) has emerged. On December 23, 2024, the 5th Circuit Court of Appeals lifted the stay previously issued by a Texas District Court, effectively reinstating the obligation for reporting companies to file Beneficial Ownership Information (BOI) reports. While the appeal is still pending, compliance with the filing requirements and deadlines remains effective. Notably, the court did not grant an automatic extension of any BOI reporting deadlines, including the January 1, 2025, deadline for companies existing before January 1, 2024, unless the company qualifies for one of the limited exemptions under the CTA.
Key Updates from FinCEN
FinCEN issued updated guidance to extend specific filing deadlines for companies impacted by the recent legal injunction. Below is a summary of the changes:
Non-exempt entities formed or registered before 2024 now have until January 13, 2025, to file the initial BOI reports, extended from the previous January 1, 2025, deadline.
Non-exempt entities formed or registered in 2024 must file within 90 days unless eligible for an extension.
Entities with a 90-day filing deadline falling between December 3 and December 23, 2024, now have until January 13, 2025, to file.
Entities created while the injunction was in effect receive an additional 21 from the original filing deadline.
Newly established entities will continue to have 30 days to file the initial BOI reports after receiving actual or public notice that their creation or registration is effective.
Entities based in disaster-impacted regions, including most Florida counties except the western panhandle, have until July 1, 2025, to file the initial BOI reports.
These extensions aim to provide additional time for compliance under the adjusted circumstances.
Stay Prepared on Beneficial Ownership Information
The court is reviewing a motion for rehearing, and additional updates may emerge in the coming weeks. Entities should closely monitor developments to ensure compliance with the CTA.
Here to Help
Check the FinCEN website for more details to ensure your business meets the upcoming deadlines. If you have any questions, we are here to help. We build value-added relationships with each client to understand their business structure and provide solid solutions. Our approach offers direct access to the firm's decision-makers. Our innovative cross-functional services help businesses address the challenges ahead.