Written By: Oded Kadosh, Guy Milhalter, and Austin Ochoa
The U.S. Court of Appeals for the Fifth Circuit has lifted the preliminary injunction that temporarily halted the enforcement of the Corporate Transparency Act’s (CTA) beneficial ownership reporting requirements. As a result, these requirements are now back in effect.
The Department of the Treasury, through FinCEN, has extended certain deadlines to account for the period during which the injunction was in effect:
- Reporting companies created or registered before January 1, 2024, now have until January 13, 2025, to file their initial beneficial ownership information reports.
- Reporting companies created or registered in the United States on or after September 4, 2024, that had a filing deadline between December 3, 2024, and December 23, 2024, have until January 13, 2025, to file their initial beneficial ownership information reports.
- Reporting companies created or registered between December 3, 2024, and December 23, 2024, have an additional 21 days from their original deadline to file.
- Reporting companies created or registered on or after January 1, 2025, must file within 30 calendar days of receiving actual or public notice of creation or registration.
This alert reflects the latest guidance following the court’s decision, and additional updates may be issued by FinCEN. We encourage businesses to review their reporting obligations and ensure compliance with the updated deadlines. Please reach out if you have any questions or require assistance.
For further details, you can review the full guidance from FinCEN here.
