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CTA Filing Requirements Revived

On December 23, 2024, the U.S. Court of Appeals for the Fifth Circuit lifted a nationwide preliminary injunction issued previously by the District Court.  The injunction barred the government from enforcing the Corporate Transparency Act’s Beneficial Ownership Filing requirements—with a deadline of December 31, 2024.  However, the impact of the Court’s stay reinstates the filing requirements, but on a slightly different schedule, per FinCEN

  • Reporting companies created or registered both before January 1, 2024, and on or after September 4, 2024, have until January 13, 2025, to file their initial beneficial ownership information reports with FinCEN;
  • Reporting companies created or registered between December 3, 2024 and December 23, 2024, have an additional 21 days to file from their original filing deadline (30 days from creation); and
  • Reporting companies created on January 1, 2025 or after, have 30 days to file their initial beneficial ownership information reports.

The bullet points above cover most non-exempt reporting companies, however, reporting companies that qualify for disaster relief may have extended deadlines.  Further, while the injunction is invalidated on a nationwide basis, it remains in place for members of the National Small Business Association as of March 1, 2024. 

For many partnerships, trusts, corporations, LLCs, and other non-exempt reporting companies, the CTA’s filing deadline is revived—and quickly approaching.  If you have any questions regarding your entity’s status under the CTA or would like assistance ensuring compliance, please contact a MacDonald Illig attorney at 814-870-7600.

 

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