The Corporate Transparency Act Will Not Go Away...

When I first learned about the Corporate Transparency Act (CTA) and the Beneficial Ownership Information (BOI) reports, I didn’t think I’d have to write three blog posts on the topic—yet here we are.

As a recap, we first wrote about the CTA and BOI to help people understand who was covered, who was exempt, how to file, etc. Then, just a few weeks ago, we wrote about the nationwide injunction enjoining the CTA.

Well, we are back; as earlier today, the Court of Appeals for the Fifth Circuit lifted the preliminary injunction blocking the enforcement of the CTA—meaning that BOI filings are back on the table.

A few hours after the Fifth Circuit’s decision, FinCEN issued a special alert stating:

“In light of a December 23, 2024, federal Court of Appeals decision, reporting companies, except as indicated below, are once again required to file beneficial ownership information with FinCEN. However, because the Department of the Treasury recognizes that reporting companies may need additional time to comply given the period when the preliminary injunction had been in effect, we have extended the reporting deadline as follows:

• Reporting companies that were created or registered prior to January 1, 2024 have until January 13, 2025 to file their initial beneficial ownership information reports with FinCEN. (These companies would otherwise have been required to report by January 1, 2025.) . . .”

So, now entities formed prior to January 1, 2024, will have until January 13th to file their BOI reports.

Hey, I am Shayn. I am the Founder of Junto Law. If you like this post, follow me on X or set a time to chat.

Disclaimer: While I am a lawyer who enjoys operating outside the traditional lawyer and law firm “box,” I am not your lawyer. Nothing in this post should be construed as legal advice, nor does it create an attorney-client relationship. The material published above is only intended for informational, educational, and entertainment purposes. Please seek the advice of counsel, and do not apply any of the generalized material above to your facts or circumstances without speaking to an attorney.