Fifth Circuit Lifts Injunction on Corporate Transparency Act: BOI Filing Deadline Reinstated for January 1, 2025

Greenberg Glusker LLP

UPDATE as of 12/24/24: FinCen has updated their website extending the beneficial ownership reporting deadline (1) for reporting companies that were created or registered prior to January 1, 2024, from January 1, 2025, to January 13, 2025, (2) for reporting companies formed after September 4, 2024, to January 13, 2025, and (3) for reporting companies formed between December 3, 2024, and December 23, 2024, an additional 21 days from their original 30-day filing deadline.

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On December 23, 2024, the U.S. Court of Appeals for the Fifth Circuit lifted the nationwide preliminary injunction that had paused enforcement of the Corporate Transparency Act (CTA). This means that entities subject to the CTA must once again comply with the original January 1, 2025 deadline for filing Beneficial Ownership Information (BOI) reports. 
 
As of now, the Financial Crimes Enforcement Network (FinCEN) has not announced any extensions to this deadline or released any public guidance. Therefore, it is essential for affected entities to act quickly to prepare and submit their BOI reports to avoid penalties for non-compliance. Here is the link to the appeals court’s order.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Attorney Advertising.

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