12/24/2024
Here's an update regarding the reporting deadline (NOW January 13, 2025) under the CTA:
CTA BREAKING NEWS: Filing Requirements Reinstated with Deadline Extensions
By Dawn Bauman, CAE and Phoebe E. Neseth, Esq. on Dec 23, 2024
On Dec. 23rd, the Fifth Circuit Court of Appeals granted a stay over the injunction issued by the U.S. District Court for the Eastern District of Texas earlier this month, and issued a court order reinstating the January 1, 2025, beneficial ownership information (BOI) filing deadline under the Corporate Transparency Act (CTA) for applicable community associations required to file under federal statute.
Given this late-breaking federal court development, FinCEN has extended reporting deadlines 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.)
• Reporting companies created or registered in the United States on or after September 4, 2024 that had a filing deadline between December 3, 2024 and December 23, 2024 have until January 13, 2025 to file their initial beneficial ownership information reports with FinCEN.
• Reporting companies created or registered in the United States on or after December 3, 2024 and on or before December 23, 2024 have an additional 21 days from their original filing deadline to file their initial beneficial ownership information reports with FinCEN.
• Reporting companies that qualify for disaster relief may have extended deadlines that fall beyond January 13, 2025. These companies should abide by whichever deadline falls later.
• Reporting companies that are created or registered in the United States on or after January 1, 2025 have 30 days to file their initial beneficial ownership information reports with FinCEN after receiving actual or public notice that their creation or registration is effective.
Learn more regarding FinCEN’s reporting deadline extensions here.
This continues to be a developing matter, but at the time of this communication applicable community associations should proceed to file their BOI reports in compliance with their applicable FinCEN deadline extension.
The Fifth Circuit Court of Appeals court order can be read here. This order is still not a final ruling on the CTA’s constitutionality. The Fifth Circuit also ordered that the appeal in this lawsuit be expedited to the next available oral argument panel.
CAI is continuing to track movements in the federal courts over CTA challenges and contacted the United States Department of Treasury today urging this administrative deadline extension due to the chaos and confusion created by these recent court rulings, Congress deciding NOT to take legislative action to extend the filing deadline, and the end of year holidays.
Please continue to visit CAI’s Corporate Transparent Act webpage for ongoing updates and additional information.
The post CTA BREAKING NEWS: Filing Requirements Reinstated with Deadline Extensions appeared first on CAI Advocacy Blog.
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