FOS would understand if business owners’ heads are spinning from the different rulings issued this holiday season under the Corporate Transparency Act (the “CTA”).
No filing requirement? Great. Now a filing requirement? In January? Really?
Well, the CTA may lose its “Grinch” nickname, at least for the moment.
On Monday, December 23, 2024, FOS advised of the Fifth Circuit Court of Appeals’ reinstatement of the CTA’s January 1, 2025 reporting obligations, while later that same day the deadline was extended to January 13, 2025 for entities formed prior to January 1, 2024 by the Financial Crimes Enforcement Network (FinCEN). https://foslaw.com/january-1-2025-cta-filing-deadline-reinstated/; https://foslaw.com/fincen-extends-cta-filing-deadline-to-january-13-2025/
Last night a different panel of the Fifth Circuit court gave businesses an extra holiday present.
The Court issued an order once again blocking enforcement of the CTA, to “preserve the constitutional status quo” while the case is under expedited appellate review.
This means that, for now, businesses do not have an obligation to file a report under the CTA.
Businesses should not let down their guard, however. A ruling in the expedited appeal could come within weeks, and entities should be prepared for all scenarios.
FOS will continue to keep clients informed of new developments or guidance and the ever-changing landscape of CTA enforcement.
