Fifth Circuit Court Ruling Reinstates Corporate Transparency Act (CTA) Deadlines
On December 23, 2024, a pivotal ruling by the Fifth Circuit Court of Appeals lifted the nationwide injunction against the Corporate Transparency Act (CTA). As a result, the previously paused Beneficial Ownership Information (BOI) reporting requirements have been reinstated under new extended deadlines announced by the Financial Crimes Enforcement Network (FinCEN).
Updated BOI Deadlines
Recognizing the period of uncertainty caused by the injunction, FinCEN has provided updated deadlines for BOI reporting:
For Companies Created or Registered Before January 1, 2024
- New Deadline: January 13, 2025.
- This replaces the original January 1, 2025, deadline.
For Companies Created or Registered Between September 4, 2024, and December 23, 2024
- New Deadline: January 13, 2025.
- This extension applies to companies with filing deadlines initially falling between December 3, 2024, and December 23, 2024.
For Companies Created or Registered Between December 3, 2024, and December 23, 2024
- New Deadline: 21 additional days from their original filing deadline.
For Companies Qualifying for Disaster Relief
- These companies may have deadlines beyond January 13, 2025, based on their specific circumstances.
For Companies Created or Registered On or After January 1, 2025
- Deadline: 30 days to file BOI reports with FinCEN following notice of creation or registration.
What Led to the Changes?
The December 23 ruling stemmed from a case, Texas Top Cop Shop, Inc. v. Garland, where a district court’s injunction on December 3, 2024, had temporarily halted the enforcement of the CTA and BOI reporting requirements. However, the Department of Justice (DOJ) appealed the decision and requested an expedited resolution.
The Fifth Circuit’s ruling indicated a strong likelihood that the government would prevail in defending the constitutionality of the CTA. In light of this, FinCEN acted promptly to extend deadlines and clarify compliance requirements for affected businesses.
What Does This Mean for Eagle Mountain Businesses?
As the injunction is no longer in effect, virtually all small businesses (unless a specific exception applies) must file their initial BOI report before the applicable deadlines listed above. If your business falls under any of the categories mentioned, ensure you meet the required deadlines to remain compliant.
The Chamber is organizing additional information sessions in the coming weeks to help small business owners comply with these filing requirements. For further guidance, reach out to your legal or financial advisors or visit FinCEN’s website for detailed instructions on filing BOI reports.
Submitted by Kenton Anderson, CPA, BGM – Tax Manager
Through the commitment and involvement of its members, the Eagle Mountain Chamber of Commerce provides business leadership for the Eagle Mountain Community by promoting G.E.A.R.S.
