There have been several developments since our last blog on December 13th, 2024, https://www.fluenceportland.com/consulting/corporate-transparency-act-cta-and-fincens-boi-reporting.
On December 23rd, 2024, the Fifth Circuit Court of appeals ruled in favor of the Justice Department lifting the injunction and reinstating the reporting requirements. The government announced a new filing deadline of January 13, 2025, for all small businesses that were required to file by January 1st.
On December 26th, the Fifth Circuit Court of Appeals reversed course, vacating the December 23rd order and reinstating the injunction. The court indicated that it wanted to preserve the constitutional status quo until it had time to rule on the merits of the case.
What does this mean to you? BOI filings are currently NOT required, and you will not be subject to a penalty if you fail to file. Many of you, including Fluence, have already filed and we still believe this is the right thing to do. For those of you who have not yet filed please make sure you keep a close eye and are ready to submit if and when a final ruling has been made. For additional information, go to https://www.fincen.gov/boi.