Breaking News Earlier today, December 23, 2024, the Fifth Circuit Court of Appeals effectively reinstated the reporting obligations and deadlines for reporting companies under the Corporate Transparency Act (CTA). The CTA, effective January 1, 2024, imposes significant reporting requirements on businesses, their owners, and their managers. On December 3, 2024, the US District Court for the Eastern District of Texas issued a preliminary injunction temporarily barring the CTA from being implemented and enforced. The Fifth Circuit today lifted the preliminary injunction, restoring the CTA filing deadlines and obligations.
While the lifting of the preliminary injunction does not, by itself, alter the compliance deadlines of the CTA, the Department of the Treasury has issued an alert through the Financial Crimes Enforcement Network (FinCEN) extending deadlines as follows:
| Formation/Registration Date* | Initial Filing Deadline | Extended Filing Deadline |
|---|---|---|
| Prior to January 1, 2024 | January 1, 2025 | January 13, 2025 |
|
On or after September 4, 2024 with initial reporting deadlines between December 3, 2024, and December 23, 2024 |
90 calendar days from formation/registration date* | January 13, 2025 |
|
On or after December 3, 2024 and on or before December 23, 2024 |
90 calendar days from formation/registration date* |
90 calendar days from formation/registration date* + 21 additional days |
| On or after January 1, 2025 | 30 calendar days from formation/registration date* | No change |
*For a domestic entity, the date of formation is the first date of (a) actual notice of formation (e.g. the Secretary of State informs the organizer the business is formed) or (b) public notice of formation (e.g. the entity shows as formed on a Secretary of State website).
*For a foreign entity, the date of registration is the first date of (a) actual notice of registration to do business in a US jurisdiction (e.g. the Secretary of State informs the organizer the business is registered) or (b) public notice of registration to do business in a US jurisdiction (e.g. the entity shows as registered on a Secretary of State website).
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Please contact Brian for questions about the BOI filing requirement or help with BOI compliance.
© 2024 Brian Berman Law, P.C. All rights reserved. This summary contains information of a general nature that is not intended to be legal advice and it does not create an attorney-client relationship between Brian Berman Law, P.C. and the reader. Each readers should consult his or her own legal counsel with respect to his or her individual circumstances and how this material may affect his or her situation. This summary may constitute attorney advertising. Prior results do not guarantee a similar outcome.
