Dear Clients,
This letter is to provide further clarity to our recent correspondence from Tuesday December 24th regarding the reinstatement of the Corporate Transparency Act and its Reporting Requirement.
On December 23, 2024, the Fifth Circuit Court of Appeals lifted the nationwide preliminary injunction that had previously blocked enforcement of the CTA.
This injunction, initially issued by the U.S. District Court for the Eastern District of Texas on December 3, 2024, is now no longer in effect. As a result, the BOI reporting obligations, along with their associated deadlines, are reinstated.
Additionally, the Financial Crimes Enforcement Network (FinCEN) has extended the deadlines for submitting BOI reports:
Entities formed or registered prior to January 1, 2024, now have until January 13, 2025, to submit their initial BOI reports (previously due by January 1, 2025).
Entities created or registered between September 4, 2024, and December 3, 2024, also have until January 13, 2025, to file their reports.
Entities registered between December 3, 2024, and December 23, 2024, are granted an additional 21 days from their original deadlines to file their initial BOI reports.
Companies that are eligible for disaster relief may have their deadlines extended beyond January 13, 2025. These companies should follow the extended deadlines accordingly.
Entities created or registered on or after January 1, 2025, will have 30 days from the date of their effective creation or registration to file their BOI reports.
We strongly advise all affected entities to carefully review these updated deadlines to ensure timely compliance with the CTA’s reporting requirements.
Failure to submit the required information by the applicable deadlines may result in fines of $500 per day and per company.
Please do not hesitate to contact Arnold Gruber, Ltd. at 330-563-4149 if you need assistance with your BOI reporting or have any questions regarding this matter.