CTA
December 24, 2024
CTA Injunction Lifted –Filing Due January 13 for Most Companies
Corporate Transparency Act
On December 23, 2024, the U.S. Court of Appeals for the 5th Circuit granted the government’s motion to lift the nationwide injunction that paused compliance with the Corporate Transparency Act (CTA). In doing so, the Court found that the government was likely to prevail in its argument that the CTA is constitutional. The Court also expedited oral arguments in the case.
The Department of Treasury’s Financial Crimes Enforcement Network (FinCEN), the agency responsible for enforcing the CTA, has provided certain extensions for reporting companies to file initial beneficial ownership reports. Companies which need to comply with the CTA should resume plans to file with FinCEN in accordance with the applicable deadline.
Companies created or registered…
before January 1, 2024
FinCEN extensions for filing beneficial ownership reports
after January 1, 2024, and before January 1, 2025
between September 4, 2024 and September 24, 2024 that have not yet filed an initial beneficial ownership report
between December 3, 2024 and December 23, 2024
had a January 1, 2025, deadline to file an initial beneficial ownership report, now extended to January 13, 2025.
have a 90-day deadline after formation or registration to file an initial beneficial ownership information report. This deadline was extended in limited circumstances.
now have until January 13, 2025
have an additional 21 days from the applicable deadline after formation or registration.
We are continuing to closely monitor developments in other pending cases challenging the CTA and will provide updates regarding any changes in the CTA’s status.
Please contact the Honigman Corporate Transparency Act Task Force or your regular firm attorney with questions regarding your company’s filing obligations.
Angela Gamalski Brandy Bruyere