As an update to our note on December 24 regarding the Corporate Transparency Act (CTA) Beneficial Ownership Information (BOI) registration deadline reinstatement: On December 26, the Fifth Circuit Court of Appeals halted the enforcement of the CTA until the case proceeds further. This action reverses the court's previous ruling from last week. While the U.S. Department of Treasury Financial Crimes Enforcement Network has not issued a notice yet, it is anticipated they will comply.
Since our December 24 update, the court delayed the previously announced reporting deadline of January 1 and extended it to January 13. It is possible the court could rule again and reinstate the January 13 CTA reporting deadline. If you have already filed your BOI report, you have nothing to worry about. If you have not filed, you now have the option to voluntarily file or wait to see what is the next ruling to come down from the Fifth Circuit understanding that if the law is found constitutional, you may have a short window to comply.
SCRLA and our national partners at NRA and AHLA will continue to keep our members updated on any further developments relating to the CTA’s registration requirements requiring broad private sector participation.
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