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UPDATE: Corporate Transparency Act (“CTA”) Reporting Is Paused Again Dec 31, 2024

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The Corporate Transparency Act is the new law that requires certain “reporting companies” (corporations or LLCs of fewer than 20 employees and $5 million or less in revenue) to report beneficial ownership information to FinCEN, the Financial Crimes Enforcement Network, or else face daily fines and up to two years imprisonment! A federal court in Texas issued a nationwide preliminary injunction in early December 2024, preventing the federal government from enforcing the law for the time being. An appeals court then changed course later in December – only to vacate its own decision days later, again pausing the reporting requirements. The result is that reporting companies are not under obligation to report – for now – but this appeal is ongoing such that the duty to report could once again come into effect. Consult your lawyer and accountant for additional guidance and go to FinCEN.gov/boi for news alerts as the situation develops. ***** Note that the criteria for reporting companies overlaps quite closely with the profile of an independent oil and gas company as defined by the IPAA, citing the IRS Code (See IPAA.org). - - - - - This message is for informational purposes only and is not, nor is intended to be, legal advice. Contact your legal counsel and accountant for additional guidance and see FinCEN FAQs at FinCEN.gov/boi.

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