On March 1, 2024, the case of National Small Business United v. Yellen resulted in a federal district court ruling that the CTA exceeds constitutional limits, leading to an injunction against its enforcement for specific plaintiffs.
Despite this, the Financial Crimes Enforcement Network (FinCEN) has expressed its intention to continue implementing the CTA, pending an appeal filed by the Department of the Treasury. This means that, except for the plaintiffs involved in the case, all reporting companies must still comply with the CTA’s requirements.
In light of these events and the potential for the decision to be overturned on appeal, we advise the following:
2. For entities formed before January 1, 2024: You have until the end of the year to file. However, we recommend not delaying the collection of necessary information and filing of a report.
Our team remains dedicated to assisting clients with their BOI reporting needs. Should you have any questions or require our services to file a BOI report, please do not hesitate to reach out.
