The Corporate Transparency Act is once again enforceable. A trial court injunction stopping enforcement of the Corporate Transparency Act (CTA) (and its Beneficial Ownership Information (BOI) reporting requirements) has been lifted by a federal appeals court. As a result, business entities must report their BOI information to FINCen promptly.

While a preliminary injunction from a trial court had temporarily suspended the January 1, 2025 deadline, the U.S. Court of Appeals for the Fifth Circuit has now reversed this decision, effectively reinstating the original compliance deadline.

In response to this development, the Financial Crimes Enforcement Network (FinCEN) has implemented a tiered deadline structure for beneficial ownership information (BOI) reporting:

• Companies established or registered before January 1, 2024, now have until January 13, 2025, to submit their initial reports – a slight extension from the original January 1, 2025 deadline.
• Companies created or registered on or after September 4, 2024, with original filing deadlines between December 3 and December 23, 2024, have been granted an extension until January 13, 2025
• Businesses established between December 3 and December 23, 2024, receive a 21-day extension from their original filing deadlines.

Key Points:

• All reporting companies must submit their Beneficial Ownership Information to FinCEN by their appropriate date
• Required information includes beneficial owners':
•     Full legal names;
•     Current residential addresses;
•     Dates of birth;
•     Identification numbers and documentation.

Given the reinstated deadline and potential penalties for non-compliance, we strongly recommend beginning your BOI reporting process immediately if you haven't already done so.

Our firm is actively monitoring these developments. We will continue to provide updates as new information becomes available.

If you have any questions or need assistance with your BOI reporting, please don't hesitate to contact us.