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In the never ending saga regarding the applicability of the Corporate Transparency Act, there is yet another twist in that the judge in the Texas litigation, which we wrote about to you on December 14 and who issued the nationwide injunction, reversed course on December 23, when he lifted the court’s previously enacted injunction making the Corporate Transparency Act’s registration requirements applicable once again. However, FinCen, in light of the short notice, has extended the deadline in which to register to January 13, 2025 absent other deadline extensions.
As reported in our prior article, a recent update from the United States Department of Treasury, Financial Crimes Enforcement Network (FinCen) provides an extension of time to comply with the requirements of the Corporate Transparency Act for the initial reporting deadlines, but there are strict requirements regarding the applicability of the extension as discussed below.
FinCen, on October 29, 2024, extended the initial reporting deadlines to June 30, 2025, for associations in counties affected by Hurricane Milton where:
(1) Federal Emergency Management Agency (FEMA) assistance is available for individual or public assistance; and
(2) IRS tax filing deadlines have been extended.
Associations in the following counties appear to be subject to the extension:
Alachua, Baker, Bradford, Brevard, Broward, Charlotte, Citrus, Clay, Collier, Columbia, DeSoto, Dixie, Duval, Flagler, Gilchrist, Glades, Hamilton, Hardee, Hendry, Hernando, Highlands, Hillsborough, Indian River, Lafayette, Lake, Lee, Levy, Madison, Manatee, Marion, Martin, Miami-Dade, Monroe, Nassau, Okeechobee, Orange, Osceola, Palm Beach, Pasco, Pinellas, Polk, Putman, Sarasota, Seminole, St. Johns, St. Lucie, Sumter, Suwannee, Taylor, Union, and Volusia.
Of course, to be absolutely certain, please check with your association’s attorney.