| On December 23, 2024, in response to the preliminary injunction issued by the Federal District Court for the Eastern District of Texas which stayed the reporting requirements of the Corporate Transparency Act (“CTA”), the U.S. Court of Appeals for the Fifth Circuit lifted the nationwide preliminary injunction. This means that reporting companies are once again required to file beneficial ownership information reports (“BOIR”) with the Financial Crimes Enforcement Network (“FinCEN”).
In response to the Fifth Circuit’s decision, FinCEN has extended reporting deadlines to allow certain reporting companies that have not yet filed an initial BOIR additional time to comply with the CTA. The extended reporting deadlines are as follows:
| Applicable Reporting Companies |
Extended Deadline |
| Reporting companies formed or registered prior to January 1, 2024:
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January 13, 2025 |
| Reporting companies formed or registered on or after September 4, 2024, that had an original filing deadline between December 3, 2024, and December 23, 2024: |
January 13, 2025 |
| Reporting companies formed or registered on December 3, 2024 – December 23, 2024: |
111 days from receiving actual or public notice that the reporting company’s formation or registration is effective |
| Reporting companies formed or registered on December 24, 2024 – December 31, 2024: |
90 days from receiving actual or public notice that the reporting company’s formation or registration is effective |
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Additionally, reporting companies that are formed or registered on or after January 1, 2025 have 30 days after formation of the company to file their initial BOIR with FinCEN.
