Corporate Transparency Act (CTA) January Update

Very recently we updated our audience about the surprising changes in the Corporate Transparency Act. That’s the federal law that requires owners of limited liability companies (LLCs), family limited partnerships (FLPs) and other entities to file a form with a new federal agency. Now we have another piece of news: a January update on the CTA.

As we explained earlier, a federal court had ruled that the entire CTA was unconstitutional, and no one would have to file. Then a federal appellate court ruled that the lower court’s injunction exceeded its authority and entities would still have to file their Business Ownership Information (BOI) reports. Then the federal agency in charge (FinCEN) gave everyone until January 13 to file, reflecting the almost two-week period during which the injunction was in effect.

Here’s the latest: the same appellate court that struck down the injunction has now restored it. For now, no one has to file and no penalties will accrue. The appellate court will hear arguments in mid-March, and we’ll see what happens then.

In the meantime, it’s actually pretty easy to file, and there’s nothing stopping LLCs and other entities from doing so. You might want to consider filing even though you don’t have to. We explain — and discuss.