As our clients know, the Fifth Circuit’s December 23, 2024 ruling reinstated the filing requirements for reporting companies under the Corporate Transparency Act (“CTA’).
After that decision, Financial Crimes Enforcement Network (“FinCEN’) extended the filing deadline to January 13, 2025 for entities formed prior to January 1, 2024. This gives reporting companies otherwise scrambling an additional twelve days to meet their reporting requirements.
FinCEN’s statement explains that, “because the Department of the Treasury recognizes that reporting companies may need additional time to comply given the period when the [Eastern District of Texas’s] preliminary injunction had been in effect,” it is extending the deadlines for reporting companies to comply. These deadlines are as follows:
- Reporting companies formed prior to 1/1/24 = January 13, 2025
- Reporting companies formed on or before 9/4/24 that had an original filing deadline between December 3rd and December 23, 2024 = January 13, 2025
- Reporting companies formed on or after 12/3/24 and on or before 12/23/24 = an additional 21 days from their original filing deadline
See “CTA Beneficial Ownership Reporting Requirements Begin January 1, 2024,” https://foslaw.com/cta-beneficial-ownership-reporting-requirements-begin-january-1-2024/ for additional information regarding whether an entity qualifies as a reporting company under the CTA. See https://foslaw.com/corporate-transparency-acts-january-1-2025-deadline-fast-approaching-for-entities-formed-before-january-1-2024/ for additional FOS guidance on the CTA.
As always, contact your FOS attorney if you have any questions or concerns about the CTA’s impact on your entities or business.
