Corporate Transparency Act Enforcement Reinstated
On December 23, 2024, the U.S Court of Appeals for the Fifth Circuit reinstated enforcement of the Corporate Transparency Act (CTA), lifting the injunction issued by a U.S. district court in Texas on December 3, 2024, in Texas Top Cop Shop, Inc. et al. v. Garland.
The appellate court found that the U.S. Department of Justice demonstrated the constitutionality of the CTA, allowing enforcement to resume while the case proceeds in the district court. Although the court of appeals’ decision does not represent a final ruling on the merits of the challenges to the CTA, the injunction that had previously halted its enforcement has been lifted. FinCEN has extended the deadlines for reporting companies to file Beneficial Ownership Information Reports (BOIR) as follows:
- Reporting companies created or registered prior to January 1, 2024: new reporting deadline of January 13, 2025 (would otherwise have been required to report by January 1, 2025).
- Reporting companies created or registered in the U.S. on or after September 4, 2024, that had a filing deadline between December 3, 2024, and December 23, 2024: new reporting deadline of January 13, 2025.
- Reporting companies created or registered in the U.S. on or after December 3, 2024, and on or before December 23, 2024: reporting deadline extended an additional 21 days from their original filing deadline.
- Reporting companies created or registered in the U.S. on or after January 1, 2025: reporting deadline is 30 days after receiving actual or public notice that their creation or registration is effective.
For assistance with BOIR filings or compliance questions, please contact our Business Services Group.
