On December 23, 2024, the Fifth Circuit Court of Appeals lifted a nationwide injunction by a lower court of beneficial ownership reports (“BOI reports”) under the Corporate Transparency Act (“CTA”).  Our previous alert on the nationwide injunction can be found here.  As a result, entities that were previously required to file these reports under the CTA are again required to do.  However, the agency that enforces the CTA, the Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”), has extended the deadlines for filing BOI reports.  The deadline extensions can be found under the “Alerts” section on FinCEN’s website.  With certain exceptions, the entities required to submit BOI reports under the CTA are those with a presence in the US, having less than $5 million in revenue and fewer than 20 full-time US-based employees.  For many entities, the new filing deadline is January 13, 2025.    

Note that the government may impose substantial penalties if filings are not made within the required period, including fines ($500/day) and possible enhanced fines and imprisonment for willful or fraudulent violations.

More information on the CTA’s reporting requirements can be found here.

Questions                                               

If you have any questions, please contact Casner & Edwards attorneys Peter Dunn, Michael Zullas, Steven Ayr, or Drew Douglas-Steele.