NEW UPDATE: Corporate Transparency Act (CTA) – Reporting Requirements Revived

The Corporate Transparency Act (CTA), which went into effect on January 1, 2024, mandates that almost all LLC owners submit annual beneficial ownership reports (BOI) to the Financial Crimes Enforcement Network (FinCEN).
However, things have been changing daily with respect to the enforcement of the CTA. Check here for updates.

2025 UPDATE

The  Supreme Court of the United States stayed the injunction blocking the enforcement of the CTA, confirming that it will allow the government to implement the Corporate Transparency Act.  What does this mean?

• The CTA’s filing requirements are now back in effect.
• FinCEN has yet to issue an updated filing deadline for reporting companies.
• The Fifth Circuit will still hear oral arguments on March 25th.

December 26, 2024: the Fifth Circuit vacated the motion panel’s stay, thereby halting enforcement once again. Further updates can be expected in March 2025, when the Fifth Circuit hears oral argument on the constitutionality of the CTA.

December 23, 2024: a three-judge panel of the Fifth Circuit stayed the lower court’s injunction, thereby reinstating the reporting obligations required under the CTA.

December 3, 2024: the U.S. District Court for the Eastern District of Texas issued a preliminary injunction barring enforcement of the CTA nationwide.

In response to the ruling, FinCEN announced an extension of the compliance deadlines, as follows, including:

• Reporting companies created or registered prior to January 1, 2024, which originally had a filing deadline of January 1, 2025, now have until January 13, 2025 to file their BOI reports.
• Reporting companies created or registered on or after September 4, 2024, which had a filing deadline between December 3, 2024, and December 23, 2024, now have until January 13, 2025 to file.
• Reporting companies created or registered on or after December 3, 2024, and on or before December 23, 2024, now have an additional 21 days from their original filing deadline to file.

Genova Burns will continue to monitor the status of any further rulings and provide the latest updates.  To find out how the deadline affects you or your business please contact us.