Dec 24, 2024
On December 23, 2024, the United States Court of Appeals for the Fifth Circuit reinstated the enforceability of the CTA which, by implication, meant that the January 1, 2025 filing deadline for “reporting companies” formed prior to January 1, 2024 was also reinstated. FinCEN responded swiftly yesterday afternoon to extend the January 1, 2025 deadline by just a few weeks with the following update: In light of a December 23, 2024, federal Court of Appeals decision, reporting companies…are once again required to file beneficial ownership information with FinCEN. However, because the Department of the Treasury recognizes that reporting companies may need additional time to comply given the period when the preliminary injunction had been in effect, we have extended the reporting deadline… FinCEN’s alert went on to list various extended compliance deadlines, the most important of which pertains to reporting companies formed prior to January 1, 2024 which now have until January 13, 2025 to file beneficial ownership information (BOI).
The full text of FinCEN’s alert can be accessed here [https://www.fincen.gov/boi].
For more information about the filing requirements under the CTA, including filing procedures and links to helpful FinCEN resources, please refer to our October 15, 2024 Client Alert (Link to Article), If you would like additional background on the legal proceedings leading up to yesterday’s decision, please refer to our December 5, 2024 Client Alert (Link to Article).
Jackson Tidus attorneys are ready to assist you in complying with the CTA and its filing requirements. Accordingly, if you have questions about the CTA or need help with filings, changes to your governance documents or other guidance or assistance, please do not hesitate to contact Jackson Tidus.
Elizabeth T. Hall, Esq.
phone: 949-851-7466
email: ehall@jacksontidus.law
Mona Goodarzi
phone: 949-851-7627
email: mgoodarzi@jacksontidus.law
This notice is provided only for informational and educational purposes. It is not offered as the Firm’s legal advice or legal opinions. You should not treat this notice as a substitute for professional legal advice. Your use of the information in this notice does not create an attorney-client relationship between the Firm or its attorneys and you. The formation of an attorney-client relationship with the Firm requires prior completion of a number of steps including resolution of possible conflicts of interest, an appropriate fee arrangement and mutual agreement on the terms of the engagement. Please do not convey to us any information that you regard as confidential until a formal attorney-client relationship has been established. Any information you convey to the Firm before establishing an attorney-client relationship may not be privileged or confidential.5