Client Alerts & Insights
FinCEN Extends Corporate Transparency Act Filing Deadlines: Companies Registered Before January 1, 2024 Have Until January 13, 2025 to File
December 24, 2024
As we previously reported, on December 3, 2024, the U.S. District Court for the Eastern District of Texas issued a nationwide preliminary injunction blocking the U.S. Department of Treasury from enforcing the Corporate Transparency Act’s (CTA) new beneficial ownership information (BOI) reporting requirements. Texas Top Cop Shop v Garland et al., 4:24-cv-00478 (Dec. 3, 2024). Then, on December 10, 2024, FinCEN alerted businesses that they did not need to report BOI while that ruling was in effect.
Then, on December 23, 2024, the Fifth Circuit Court of Appeals stayed the Eastern District of Texas preliminary injunction, restoring the January 1, 2025, initial filing deadline.
On December 24, 2024, FinCEN issued an Alert extending certain deadlines to file beneficial ownership information reports:
- Reporting companies created or registered before January 1, 2024 have until January 13, 2025 to file.
- Reporting companies created or registered on or after September 4, 2024 that had a filing deadline between December 3, 2024 and December 23, 2024 have until January 13, 2025 to file.
- Reporting companies created or registered on or after December 3, 2024 and on or before December 23, 2024 have an additional 21 days from their original filing deadline to file.
- Reporting companies created or registered on or after January 1, 2025 have 30 days to file.
Companies should continue working with knowledgeable counsel to comply with BOI reporting requirements. If you have questions regarding the CTA or the impact of the Texas Top Cop Shop decision, the White Collar and Corporate & Securities Practice Groups at Benesch are here to help.
Marisa T. Darden at mdarden@beneschlaw.com or 216.363.4440.
Robert J. Kolansky at rkolansky@beneschlaw.com or 216.363.4575.
Jennifer L. Stapleton at jstapleton@beneschlaw.com or 216.363.4428.
Connie A. Porter at cporter@beneschlaw.com or 216.363.4433.
Latest News
Science-Backed But Not FDA-Approved: New Lawsuit Challenges FDA’s Rejection of 114 Health-Related Advertising Claims
A new lawsuit challenges the FDA’s rejection of 114 health-related advertising claims for supplements, arguing that the agency’s narrow interpretation of what counts as an “authoritative statement” unfairly blocks science-backed—but not FDA-approved—claims from appearing on product labels.
When ChatGPT Lies: What the First Wave of AI Defamation Cases Means for Plaintiffs
The common argument made by plaintiffs that differences in alleged misrepresentations are transcended by the center of the gravity of the alleged fraud should not be addressed through the typical approach of just comparing the level of variance of the representations in the case at issue with that in the relevant precedent.
Delaware Adopts Uniform Assignment for the Benefit of Creditors Act, Expanding Bankruptcy Alternative for Distressed Companies
Customs compliance and enforcement defense are high-profile exercises within U.S.-based importers due to the higher-risk regulatory enforcement environment. One of the more complex hot topics facing compliance and legal professionals within importers of record (IORs) is the degree to which “assists” impact dutiable value, and therefore duty burden, in the eyes of U.S. Customs and Border Protection (CBP).
Feds Set Their Sights on Ohio: Unpacking the Federal-State Partnership
Customs compliance and enforcement defense are high-profile exercises within U.S.-based importers due to the higher-risk regulatory enforcement environment. One of the more complex hot topics facing compliance and legal professionals within importers of record (IORs) is the degree to which “assists” impact dutiable value, and therefore duty burden, in the eyes of U.S. Customs and Border Protection (CBP).