This is an important follow-up to our Tuesday, Dec. 10, 2024, Client Alert regarding the recent injunction prohibiting enforcement of the Corporate Transparency Act (“CTA”).
As of Dec. 31, 2024, companies are not required to file Beneficial Ownership Reports (“BOI Reports”) with the Financial Crimes Enforcement Network (“FinCEN”). This alert simply aims to provide clarity on recent CTA developments which have occurred over the last two weeks.
On Monday, Dec. 23, 2024, the U.S. Court of Appeals for the Fifth Circuit restored the enforceability of the CTA, which meant, at the time, that reporting companies were once again required to file BOI Reports with FinCEN. Upon this restoration, FinCEN issued an extension of most filing deadlines to Jan. 13, 2025, giving companies an extra two-week period to file. However, just three days after the Dec. 23 decision, on Dec. 26, the ruling was reversed by a Fifth Circuit “Merits Panel”, and the CTA was once again determined to be unenforceable.
This is to simply clarify any confusion regarding filing requirements. Once again, as per the Fifth Circuit’s Dec. 26 ruling, companies are currently not required to file BOI Reports with FinCEN. As is evident, the situation is continuously developing, and the Business Services Group at Bose McKinney & Evans LLP (“BME”) remains committed to keeping you updated as new developments arise. We strongly encourage you to reach out with any questions you may have.
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