Federal Court Reinstates CTA Reporting Obligations Effective Immediately

On December 23^rd, the United States Court of Appeals for the Fifth Circuit revived the immediate enforceability of the Corporate Transparency Act, staying a lower court’s nationwide preliminary injunction against the CTA issued back on December 3^rd. This means that reporting companies are once again obligated to file their Beneficial Ownership Information reports with FinCEN. However, the Department of the Treasury has extended certain reporting deadlines as follows:

• Reporting companies that were created or registered prior to January 1, 2024 have until January 13, 2025 to file their initial beneficial ownership information reports with FinCEN. (These companies would otherwise have been required to report by January 1, 2025.)

• 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 with FinCEN.

• Reporting companies created or registered in the United States on or after December 3, 2024 and on or before December 23, 2024 have an additional 21 days from their original filing deadline to file their initial beneficial ownership information reports with FinCEN.