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Corporate Transparency Act Injunction Lifted: Initial Reporting Deadline Extended to January 13, 2025

December 26, 2024 |
By Councilor.

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Date:
December 26, 2024
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CTA reporting remains uncertain as BOI deadlines shift and enforcement guidance continues to evolve.

On December 23, 2024, the Fifth Circuit Court lifted the injunction, allowing FinCEN to enforce Beneficial Ownership Information (BOI) reporting.  This injunction had temporarily halted the requirement for companies to comply with the Corporate Transparency Act’s (CTA) reporting rules, which were set to take effect on January 1, 2025.

In response to the stay by the Fifth Circuit, FinCEN of the U.S. Department of Treasury published the following modified CTA reporting deadlines for submitting initial BOI reports:

  • Companies created before January 1, 2024, have until January 13, 2025, to file.
  • Companies created between September 4, 2024, and December 23, 2024, have until Jan. 13, 2025, to file.

We’re Closely Monitoring Evolving CTA Developments

With the potential for further appeals, we’re here to keep you informed on this evolving issue and its impact on your business. Whether you need clarity on compliance, help gathering information, or filing guidance, our team at CBM is ready to assist. Contact us today to discuss how these changes may affect your business and develop a strategy that works for you.

Update: As of December 26, the publication date of this update, the injunction against enforcement of BOI reporting requirements has been reinstated, reversing an earlier order from this week. CBM will provide updates as more information becomes available.

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