Corporate Transparency Act Reinstated with Extended Deadlines

UPDATE: As of December 26, 2024, the Appellate Court has lifted its own stay on the injunction and the CTA is now enjoined again pending its expedited appeal. Reinhart will continue to monitor updates.

On December 23, 2024, the U.S. Court of Appeals for the Fifth Circuit granted an emergency stay of a nationwide preliminary injunction previously blocking enforcement of the Corporate Transparency Act (CTA). We discussed the injunction here. As a result of the stay issued by the appellate court, the lower court’s injunction is dismissed, the CTA is once again in effect and reporting deadlines have been reinstated.

The Financial Crimes Enforcement Network (FinCEN) has extended certain deadlines due to the uncertainty that resulted from the previous injunction. In a notice posted on FinCEN’s website, FinCEN has provided updated deadlines to file initial Beneficial Ownership Information Reports as follows:

• Reporting Companies created prior to January 1, 2024, now have a deadline of January 13, 2025 (previously January 1, 2025).
• Reporting Companies created on or after September 4, 2024, now have a deadline of January 13, 2025 (previously December 3, 2024 through December 23, 2024).
• Reporting Companies created between December 3, 2024 and December 23, 2024, now have a deadline extended 21 days from their original filing deadline.
• Reporting Companies created on or after January 1, 2025, continue to have a deadline of 30 days after creation.

Reinhart will continue to monitor developments regarding the enforcement of the CTA. For more information and questions, please contact your Reinhart attorney.