Further Update on this Week’s Breaking News Alert – 5th Circuit Court of Appeal Vacates Its Stay Pausing, Once Again, the Corporate Transparency Act’s Filing Deadline
Late in the evening on December 26, 2024, the 5th Circuit Court of Appeals in the case of Texas Top Cop v. Garland vacated its ruling granting the United States’ Motion for a Temporary Stay pending appeal on the enforcement of the Corporate Transparency Act.
While the bar keeps moving, and we continue to keep you informed, we now are acting under this latest ruling that once again prohibits the United States Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) from enforcing any aspect of the Corporate Transparency Act’s disclosure requirements against “Reporting Companies” (like an Association) while the appeal is pending.
While the reporting requirements are stayed once again, your community may also qualify for a six-month extension due to this year’s hurricanes. The following counties qualify for the six-month extension:
Alachua, Baker, Bradford, Brevard, Broward, Charlotte, Citrus, Collier, Columbia, DeSoto, Dixie, Duval, Flagler, Gilchrist, Glades, Hamilton, Hardee, Hendry, Hernando, Highlands, Hillsborough, Indian River, Lafayette, Lake, Lee, Levy, Madison, Manatee, Marion, Miami-Dade, Monroe, Okeechobee, Orange, Osceola, Palm Beach, Pasco, Pinellas, Polk, Putnam, Sarasota, Seminole, St. Johns, St. Lucie, Sumter, Suwannee, Taylor, Union, and Volusia.
Remember to consult with your association counsel regarding the new statutory and federal reporting requirement applicable to your association prior to the looming deadlines.