Corporate Transparency Act Reporting Requirements Back in Effect With Deadline Extensions

Key Takeaways

• Reporting companies that were created or registered before 2024 have until Jan. 13, 2025, to file their initial beneficial ownership information reports. These companies would otherwise have been required to report by Jan. 1, 2025.
• Previously, a federal district court in Texas issued a nationwide preliminary injunction that temporarily put enforcement of the Corporate Transparency Act (CTA) on hold.
• The United States Court of Appeals for the Fifth Circuit has granted an immediate stay of the nationwide injunction, meaning that the injunction is not currently in effect.
• The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has acknowledged that reporting companies may need additional time to comply with the CTA given the period when the preliminary injunction was in place. FinCEN has extended the reporting deadline for pre-2024 entities, as well as the following deadlines:
  
  
  • Reporting companies created or registered on/after Sept. 4, 2024, that had a filing deadline between Dec. 3, 2024, and Dec. 23, 2024, have until Jan. 13, 2025, to file their initial beneficial ownership information reports.
  • Reporting companies created or registered on/after Dec. 3, 2024, and on/before Dec. 23, 2024, have an additional 21 days from their original filing deadline to file their initial beneficial ownership information reports.
• We recommend that reporting companies (and others affected by the CTA) resume compliance with the CTA and timely file all necessary reports and updates.