December 24, 2024: The Department of Treasury has extended the reporting deadline for reporting companies that were created or registered prior to January 1, 2024. Companies that meet this criterion now have until January 13, 2025, to file their initial beneficial ownership information (BOI) reports with FinCEN. These companies would otherwise have had a January 1, 2025, deadline for their initial BOI reports.
Appeals Court Reinstates Corporate Transparency Act Disclosure Deadline
The Fifth Circuit Court of Appeals has granted the government’s emergency motion to stay a Texas district court’s nationwide injunction against the Corporate Transparency Act (CTA), reinstating the original CTA disclosure deadline. If you have not filed yet, please note that the CTA disclosure deadline for all specified businesses formed prior to 2024 is January 13, 2025 (original due date of January 1, 2025).
This news comes on the heels of a federal district court’s ruling earlier this month in which a nationwide preliminary injunction against enforcing the beneficial ownership information (BOI) reporting requirements mandated by the CTA was put in place (Texas Top Cop Shop v. Garland (December 3, 2024) U.S. Dist. Ct., Eastern Dist. Of Texas, Case No. 4:24-CV-478). The December 3 ruling was widely expected to be appealed by the government and as of December 23, 2024, The Fifth Circuit lifted the nationwide injunction, finding that the federal government is likely to prevail in a constitutional challenge to the law. If you have not filed your BOI reports yet, please proceed with your compliance efforts before the deadline. You should also consult with legal counsel on any questions related to your specific circumstances.
Reporting companies that were created or registered in the United States after January 1, 2024, should also refer to FinCEN’s website to review the Alert summarizing those filing deadlines.
Not sure what to do next? Read our blog post, The Corporate Transparency Act (CTA): What You Need to Know, to learn more about key reporting requirements, timelines, and tips for filing. For additional assistance, please contact us or reach out to your Perkins advisor.