Last week, the US District Court for Eastern District of Texas ruled on reporting under the Corporate Transparency Act, issuing a nationwide injunction against its enforcement. The CTA otherwise required entities to report Beneficial Ownership Information on or before January 1, 2025. While this injunction is not permanent, we will suspend filings for companies until the injunction is overturned on appeal.
Kotz Sangster Wysocki P.C., a leading business law firm based in Detroit, has announced that attorney Douglas Eyre has joined the firm in its Detroit office. Eyre is a seasoned attorney, bringing over 20 years of experience in construction law and commercial litigation to the firm.
As previously shared, on Tuesday, December 3rd, 2024, the US District Court for the Eastern District of Texas issued an order specifically prohibiting the federal government’s enforcement of the Corporate Transparency Act (CTA), which was enacted January 1st, 2024. The Act requires all applicable US companies (~32.5 million, as of January 1st, 2024) to provide the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) with far-reaching “beneficial owners information” (BOI) by January 1st, 2025.
As of December 23rd, 2024, the federal US Court of Appeals for the Fifth Circuit issued an updated ruling reinstating the CTA’s reporting requirements, overturning the Texas court’s previous ruling. FinCEN has extended the previous information submission deadlines to accommodate the ongoing implementation uncertainty.
The extended reporting deadlines are as follows:
Businesses created before January 1st, 2024 – New deadline of January 13th, 2025
Businesses created on or after September 4th, 2024 – New deadline of January 13th, 2025
Businesses created between December 3rd-23rd, 2024 – New deadline of 21 days from their original filing deadline
Businesses created on or after January 1st, 2025 – New deadline of 30 days after notice of business registration confirmation
Businesses that qualify for disaster relief may have deadlines later than those listed above. In those circumstances, those businesses have been instructed by the Fifth Circuit court to use whichever deadline date is later.
Kotz Sangster will resume filings for companies and will continue to keep our clients informed regarding future implementation of the CTA as the situation continues to evolve.
