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On December 23, 2024, the Fifth Circuit Court of Appeals lifted the nationwide injunction that halted enforcement of the reporting requirements under the Corporate Transparency Act (CTA) earlier this month. FinCEN, which enforces the CTA, provided an alert soon after the ruling that updates the deadlines for reporting companies to file their Beneficial Ownership Interest Report. Those deadlines are as follows:
- Reporting companies created or registered before January 1, 2024, have until January 13, 2025, to file initial BOI reports with FinCEN. (These companies would otherwise have been required to report by January 1, 2025.)
- Reporting companies created or registered in the United States on or after September 4, 2024, that had a filing deadline between December 3, 2024, and December 23, 2024, have until January 13, 2025, to file initial BOI reports with FinCEN.
- Reporting companies created or registered in the United States on or after December 3, 2024, and on or before December 23, 2024, have an additional 21 days from their original filing deadline to file initial BOI reports with FinCEN.
- Reporting companies that qualify for disaster relief may have extended deadlines that fall beyond January 13, 2025. These companies should abide by whichever deadline falls later.
- Reporting companies that are created or registered in the United States on or after January 1, 2025, have 30 days to file initial BOI reports with FinCEN after receiving actual or public notice that their creation or registration is effective.
It remains unclear whether the new presidential administration taking office in January will take action regarding the CTA. Provident Law continues to monitor the situation and will provide alerts of any additional developments. If you have any questions or need assistance to comply, please feel free to contact our Firm.
Kyle McCutcheon is an attorney at Provident Law. His practice areas include business, real estate, and estate planning as well as advising church and nonprofit tax-exempt organizations. McCutcheon is licensed to practice law in Arizona and Missouri, and he can be reached at kyle.mccutcheon@ProvidentLawyers.com or at 480-388-3343.
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