On December 23, 2024, the U.S. Court of Appeals for the Fifth Circuit stayed a district court’s preliminary injunction that temporarily prevented the enforcement of the Corporate Transparency Act (CTA) in the Texas Top Cop Shop, Inc. v. Garland case. This stay reinstates the CTA’s beneficial ownership information (BOI) reporting requirements. While litigation on the CTA continues, covered entities are now required to report BOI to FinCEN to avoid penalties. To account for the previous injunction, FinCEN announced updated reporting deadlines on its website as follows:
- Entities formed or registered before January 1, 2024, must submit BOI reports by January 13, 2025.
- Entities formed or registered between September 4, 2024, and December 23, 2024 have until January 13, 2025
- Those formed between December 3 and December 23, 2024, have an additional 21 days beyond their original deadline.
- Reporting companies that are created or registered in the United States on or after January 1, 2025, have 30 days to file their initial beneficial ownership information reports with FinCEN after receiving actual or public notice that their creation or registration is effective.
We will continue to monitor the situation and update you as more information becomes available.
Please note that this alert is for informational purposes only and does not constitute legal advice.