Hello
Late Monday, December 23rd, a three-judge panel of the New Orleans-based 5th U.S. Circuit Court of Appeals overturned the nationwide injunction issued earlier this month by
a federal judge in Texas who had concluded that the Corporate Transparency Act was unconstitutional.
A couple of hours later, FinCEN extended the filing deadline for reporting companies that had been required to supply BOI information by Jan. 1. Their new filing deadline was Jan. 13.
Reporting deadlines were extended as follows:
- Reporting companies created or registered before Jan. 1, 2024, have until Jan. 13, 2025, to file initial BOI reports with FinCEN. (These companies would otherwise have been required to report by Jan. 1, 2025.)
- Reporting
companies created or registered in the United States on or after Sept. 4, 2024, that had a filing deadline between Dec. 3, 2024, and Dec. 23, 2024, have until Jan. 13, 2025, to file initial BOI reports with FinCEN.
- Reporting companies created or registered in the United States on or after Dec. 3, 2024, and on or before Dec. 23, 2024, have an additional 21 days from their original filing deadline to
file initial BOI reports with FinCEN.
- Reporting companies that qualify for disaster relief may have extended deadlines that fall beyond Jan. 13, 2025. These companies should abide by whichever deadline falls later.
- Reporting companies that are created or registered in the United States on or after Jan.
1, 2025, have 30 days to file initial BOI reports with FinCEN after receiving actual or public notice that their creation or registration.
Isn’t this fun!! Stay tuned for the next punchline in the joke.
Lee Phillips, JD
United States Supreme Court Counselor