The filing requirement for the Corporate Transparency Act (CTA) has been reinstated by the Fifth Circuit of the United States Court of Appeals with a new deadline of January 13th, 2025. We previously alerted you that on December 3, 2024, a nationwide preliminary injunction was issued by the U.S. District Court for the Eastern District of Texas temporarily halting enforcement of the CTA and its beneficial ownership information (BOI) reporting requirements.
In light of this Court of Appeals decision on December 23, 2024, all companies formed before or after January 1, 2024 must comply with the filing requirements of the CTA and associated regulations issued by the Treasury Department’s Financial Crimes Enforcement Network (FinCen).
There has been no updated guidance from FinCen since the Court of Appeals decision on the reinstatement of the filing deadline, so we recommend that companies continue to gather information for filing and aim to file by the January 13, 2025 deadline. If there is any extension or further guidance from FinCen that would affect this upcoming deadline, we will inform you.
