Hello, everyone. I wanted to take a moment to update you on some recent developments regarding the Corporate Transparency Act, or CTA, and the reporting requirements for Beneficial Ownership Information, or BOI.
I was originally going to share with you that the U.S. House of Representatives introduced a resolution to extend the BOI reporting deadline for companies formed or registered before January 1, 2024.
However, on December 21, Congress passed its budget bill, which did not include an extension for the BOI reporting deadline. While earlier drafts had proposed moving the deadline from January 1, 2025, to January 1, 2026, that provision was ultimately removed in the final version.
So, as things stand now, businesses subject to BOI reporting must meet the original January 1, 2025 deadline unless something changes.
In another significant update on December 23, the Fifth Circuit Court of Appeals granted the government’s emergency motion to stay the nationwide preliminary injunction issued by a federal court in Texas. To give you some background: that injunction had temporarily halted enforcement of the CTA and its associated deadlines. However, with Monday’s order, the injunction is now on hold as the government’s appeal moves forward.
In simpler terms: while there was some uncertainty about whether reporting was mandatory due to the injunction, that confusion is now cleared up. Compliance with BOI reporting requirements is once again mandatory, with the original deadline of January 1, 2025 still in place, at least for now.
Here’s what you need to know:
- The Corporate Transparency Act is back in effect. The BOI reporting requirements and deadlines are once again enforceable, pending the outcome of the government’s appeal.
- The January 1, 2025 deadline still stands. Unless there are further developments, businesses subject to BOI reporting must comply with this deadline.
- The government’s appeal is being expedited. The Fifth Circuit is prioritizing this matter and has ordered an expedited review of the appeal, including oral arguments before the next available panel.
So, if you’re one of the businesses affected by the CTA’s BOI reporting requirements, it’s time to make sure you’re on track for the January 1, 2025 deadline. Stay tuned for further updates, but for now, the reporting obligation is very much back in play.
If you need assistance completing these filings, reach out to us immediately to get your forms filed. Failing to submit information on time can result in a $591 penalty per day. We can be reached at 310-534-5577 or [email protected].
