Please note that this blog post was published on December 26, 2024, and now contains information that is no longer current. For the most up-to-date information regarding the Corporate Transparency Act, please refer to our latest blog post.By Jessica S. Kaczinski and Ian T. ReillyThe cusp of the new year brings renewed obligations under the Corporate Transparency Act (CTA), and a narrow window for compliance. Earlier this month, we informed you of a Texas federal court’s nationwide injunction which temporarily blocked enforcement of the CTA’s Beneficial Owner Information (BOI) reporting rules. At that time, we advised you that the year-end filing deadline was effectively halted, and we stopped filing BOI reports for all clients accordingly. We also cautioned you that the injunction was only temporary and could be set aside or reversed.On December 23, 2024, the Fifth Circuit Court of Appeals granted the Department of Justice’s motion to overturn the Texas Court’s injunction on the grounds that “a last-minute nationwide preliminary injunction would undermine [the federal government’s] ability to push other countries to reform their anti-money laundering and counterterrorism regimes and to address the most fundamental gap in our own regime.” This decision reinstates the federal government’s authority to enforce the CTA and reactivates the requirement for businesses to file BOI reports.Contrarily, the Court was unsympathetic to the plight of business owners, noting that “…the district court’s preliminary injunction has only been in place for less than three weeks as compared to the nearly four years that [they’ve] have had to prepare since Congress enacted the CTA.”To address the reinstatement of the BOI filing requirements only seven days before the original filing deadline, the Financial Crimes Enforcement Network (FinCEN) has extended the January 1, 2025, deadline to January 13, 2025. This narrow window necessitates swift action on the part of any corporations, limited liability companies, and other similar business entities required to file under the CTA.Here’s what the new timeline for CTA compliance may mean for you: Existing Reporting Companies: Companies created or registered in the U.S. before January 1, 2025, must file their BOI reports by January 13, 2025. Recently Formed Companies (formed Sept. 4–Dec. 23, 2024): Companies with filing deadlines that fell between December 3 and December 23, 2024, now have until January 13, 2025, to submit initial BOI reports. Newly Formed Companies (formed Dec. 3–Dec. 23, 2024): Companies created or registered during this period have an additional 21 days from their original filing deadline to submit their reports. Future Filings: Companies created or registered in the U.S. on or after January 1, 2025, will have 30 days from their creation or registration date to file their BOI reports.While we expect further action on this decision and the long-term enforceability of the CTA, nothing is likely to happen before January 13, 2025, and the reinstated deadline leaves little leeway in the interim. With draconian penalties for non-compliance reaching up to $10,000 and potential imprisonment, it’s imperative that you take all necessary steps to meet these BOI reporting requirements if you have not done so already. If you have questions or concerns about your BOI filing, please contact your Gross McGinley attorney today.