We recently sent you communications regarding the nationwide block of the Corporate Transparency Act (“CTA”) by a Texas federal court.
We’re now learning new and timely information indicating that the CTA initial reporting deadline of January 1, 2025 for entities that existed on January 1, 2024, as well as any additional filings previously required for new entities formed during 2024 or 2025 may be in effect based on an imminent potential stay motion (see below) affecting the current injunction.
What this means is there still may be a requirement for all affected companies to comply with all CTA filing requirements. However, we are still waiting for a court decision regarding whether the injunction will remain in effect or be stayed. Simply put, if the injunction is stayed (overturned), this means that all filing requirements will be in effect as though there was no injunction. Therefore, the January 1, 2025 filing deadline and all other filing deadlines will need to be complied with. The Fifth Circuit Court could make a decision regarding the motion for stay as early as December 19, 2024. As of the release of this communication, we do not know when this will actually be resolved.
If you’re unsure how to proceed, it is in your best interest to speak to your attorney. They are best equipped to help you through the CTA process.
Keep in mind, businesses may still voluntarily submit BOI reports, according to the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN).
We’ll continue to monitor the situation and keep you updated. In the meantime, feel free to reach out to the Cg Team with questions.