Navigating the Corporate Transparency Act (CTA) Amid Legal Uncertainty
The Corporate Transparency Act (CTA) and its Beneficial Ownership Information (BOI) reporting requirements are currently in flux due to recent legal developments. Here’s what you need to know to stay informed and prepared.
Background on the CTA
The CTA requires many smaller corporations and LLCs to file a BOI report with FinCEN, identifying individuals who own or control the entity. Originally:
Businesses formed before 2024 were required to file by January 1, 2025.
Businesses formed in 2024 had a 90-day window to file.
However, recent court rulings have disrupted these deadlines.
Current Status
As of January 1, 2025, a nationwide injunction has delayed all BOI filing requirements. During this injunction:
Filing deadlines are suspended, and no penalties apply for non-filing.
The injunction affects:
Businesses formed before 2024 with the original January 1, 2025, deadline.
Businesses formed in 2024 with a 90-day filing deadline.
Businesses needing to update filings due to ownership or control changes.
Voluntary Filing Option
Although filing is not currently required, entities may choose to file voluntarily. Filing early can help you avoid the rush if the injunction is lifted unexpectedly.
Key Takeaways
No immediate action is required, but it’s smart to prepare by gathering the necessary information, such as ownership and control details.
If you’ve already filed, no further steps are needed unless there are updates to report.
Stay informed about developments to ensure compliance if the deadlines are reinstated.
If you have any questions or need assistance preparing for BOI reporting, we’re here to help guide you through this process.