Dear Clients and Friends:
On Monday, December 23, 2024, a federal appeals court issued a stay on the nationwide preliminary injunction previously issued by a federal district court on December 3, 2024. This new ruling means that the Corporate Transparency Act (the “Act”) and the reporting requirements thereunder are back in effect for the time being, pending appeal. Recognizing the uncertainty business owners may have been experiencing due to the various court rulings, FinCEN has offered brief extensions of some of the reporting deadlines. Unless and until further action is taken by the courts, Congress, or FinCEN, all Reporting Companies must comply with the Act and are once again required to file Beneficial Ownership Information Reports (“BOI Reports”) with FinCEN by the following extended reporting deadlines:
- Reporting Companies that were created prior to January 1, 2024, have until January 13, 2025 to file their BOI Reports.
- Reporting Companies created 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 BOI Reports.
- Reporting companies created between December 3, 2024 and December 23, 2024 have an additional 21 days from their original filing deadline (i.e., 111 days from formation rather than 90 days from formation) to file their initial BOI Report.
- Reporting companies that are created on or after January 1, 2025 still have 30 days to file their initial BOI Report.
The full alert from FinCEN setting forth the extended reporting deadlines is available here: https://fincen.gov/boi. Please contact your HH&K Attorney with any questions regarding compliance with the Act or for assistance with filing the BOI Report for your entity. We will continue to keep you apprised of any further updates regarding these matters.
This Client Alert is not a substitute for legal guidance regarding program details and how those may be applicable to your business. As always, if we can be of assistance with these programs or any other matters, please do not hesitate to contact your HH&K attorney.
Click here for a printable version of this Client Alert.
Client Alert Date: December 26, 2024
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Erica L. Lawson |
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Thomas A. Conlon, Jr. |
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Christina J. Graziadei |
Copyright © 2024 by Hinman, Howard & Kattell LLP. This Client Alert is provided as a general information service to clients and friends of Hinman, Howard & Kattell, LLP. It should not be construed as, and does not constitute legal advice on any specific matter, nor does this message create an attorney-client relationship. These materials may be considered Attorney Advertising in some states.