As noted in our Dec. 23, 2024, eAlert, filing obligations and enforcement of the Corporate Transparency Act (CTA) are again in effect following issuance of an order by the Fifth Circuit Court of Appeals staying the injunction previously issued in Texas Top Cop Shop, Inc. v. Garland.
In a bit of holiday magic, later that same evening, the U.S. Financial Crimes Enforcement Network (FinCEN) issued a notice briefly extending the deadlines for many reporting companies to file their initial beneficial ownership reports:
- Reporting companies created or registered in the U.S. before Jan. 1, 2024, now have until Jan. 13, 2025, to file their initial beneficial ownership reports (extended from Jan. 1, 2025).
- Reporting companies created or registered in the U.S. on or after Sept. 4, 2024, now have until Jan. 13, 2025, to file their initial beneficial ownership report (extended from 90 days after the date of formation or registration).
- Reporting companies created or registered in the U.S. on or after Dec. 3, 2024, and on or before Dec. 23, 2024, now have an additional 21 days to file their reports (effectively extending the deadline from 90 to 111 days after formation/registration).
Reporting companies created or registered in the U.S. on or after Jan. 1, 2025, must file their initial beneficial ownership reports within 30 days of formation. There was no change to this deadline.
Reporting companies created or registered in the U.S. before Sept. 4, 2024, are still required to file their initial beneficial ownership information report within 90 days of formation. FinCEN has not extended this deadline. If you formed an entity between Jan. 1, 2024, and Sept. 4, 2024, and have not yet filed an initial beneficial ownership information report, you should do so as soon as possible.
Certain entities that qualified for disaster relief in connection with specific, named, weather events now must file by the later of Jan. 13, 2025, or their previously extended filing deadline.
While these extensions provide some relief over the holiday season, Jan. 13, 2025, will come quickly. We encourage clients to submit their beneficial ownership information online as soon as possible. For more details on the required information and process for reporting, please see our prior eAlert.
