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For the most recent update regarding this news, <a href="https://www.michaelbest.com/Newsroom/357702/Enforcement-of-the-Corporate-Transparency-Act-Enjoined-Again-While-Appeal-is-Heard">please click here</a>.

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Please read this notice in its entirety as it contains important updates to a prior alert that was issued regarding the enforcement of the Corporate Transparency Act (the “CTA”).

On December 3, 2024, enforcement of the CTA was enjoined by a preliminary injunction issued by the U.S. District Court for the Eastern District of Texas. However, on December 23, 2024, the United States Court of Appeals for the Fifth Circuit issued a stay on that preliminary injunction.

After this most recent decision, the reporting requirements (“BOI Reports”) are back in place, but with delayed reporting deadlines.

Date of Entity Creation or Registration

Reporting Deadline

January 1, 2024 – September 3, 2024

Within 90 days of creation or registration

September 4, 2024 – September 24, 2024

September 25, 2024 – December 2, 2024

December 3, 2024 – December 23, 2024

An additional 21 from their original filing deadline (within 111 days of creation or registration)

December 24, 2024 – December 31, 2024

Within 30 days of creation or registration

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On December 3, 2024, the U.S. District Court for the Eastern District of Texas granted a preliminary injunction enjoining enforcement of the CTA. The decision held that the “[t]he CTA finds no constitutional solace behind any door.” For a more in depth discussion of the previous stay, please see our alert <a href="https://www.michaelbest.com/Newsroom/356005/Texas-District-Court-Stays-Corporate-Transparency-Act-Reporting-Requirements">here</a>.

However, on December 23, 2024, the Fifth Circuit held that the United States has adequately shown that it is likely to succeed on the merits. As a result, the Fifth Circuit issued a stay on the District Court’s preliminary injunction, blocking its enforcement and reinstating the requirements of the CTA and the BOI Reports.

Recognizing the complexity of the situation, the Department of the Treasury and FinCEN have delayed the reporting deadlines to provide reporting companies with additional time to file.

Michael Best has attorneys who can advise companies on the issues relating to the CTA and can help those companies comply with their reporting requirements. Please contact a member of our team for more information.

To continue receiving alerts of this nature, please <a href="https://sites-michaelbest.vuturevx.com/5/2428/landing-pages/subscribe.asp?_gl=1*x2txr9*_ga*MTI3NzM3MzQ2LjE3Mjg5MjQ0MjU.*_ga_H30M0JWHW0*MTczMDczNjU4My41Mi4wLjE3MzA3MzY1ODMuMC4wLjA.">subscribe here</a>.

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Corporate Transparency Act Beneficial Ownership Reporting Requirements Are Back in Effect

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