On December 23, 2024, the Fifth Circuit Court of Appeals granted a stay of the preliminary injunction preventing the U.S. Treasury Department and its Financial Crimes Enforcement Network (FinCEN) from enforcing the Corporate Transparency Act (CTA) against all companies nationwide.
Accordingly, all non-exempt reporting companies are once again required to file their CTA Beneficial Ownership Information Reports. However, FinCEN just extended the filing deadlines as follows:
- For companies formed before 2024, the extended filing deadline is January 13, 2025.
- For companies formed on or after September 4, 2024, and on or before September 24, 2024, the extended filing deadline is January 13, 2025.
- For companies formed on or after December 3, 2024, and on or before December 23, 2024, the filing deadline is 90 days plus an additional 21 days.
- For companies formed on or after January 1, 2025, the filing deadline is 30 days after formation (i.e., no extension of the deadline).
If your company has not yet filed its CTA report and is not exempt from filing, we recommend that you take all necessary steps to file on a timely basis.
If you have any questions, please contact Edmund G. Kauntz at [email protected] or Nathaniel D. Tucker at [email protected] or via telephone at 216-292-5807.
