UPDATE: CTA INJUNCTION STAYED - REPORTING DEADLINES EXTENDED

UPDATE: On December 23, 2024 the Fifth Circuit Court of Appeals issued an Order, effective immediately, granting the government’s emergency motion to stay the nationwide injunction previously issued by a United States District Court on December 3, 2024. This means that all reporting companies under the Corporate Transparency Act (CTA) are once again required to file their beneficial ownership information (BOI) reports.

In response, on December 23, 2024, FinCEN announced the following extended filing deadlines:

• For reporting companies in existence prior to January 1, 2024, the new reporting deadline is January 13, 2025.
• For newly-formed reporting companies created between September 4, 2024 through December 2, 2024, the new reporting deadline is January 13, 2025.
• For newly-formed reporting companies created on or after December 3, 2024 and on or before December 23, 2024, the new reporting deadline is their applicable original reporting deadline plus 21 days.
• For newly-formed reporting companies created on or after January 1, 2025, the reporting deadline remains 30 days after formation to file their completed BOI reports.

While there may be additional judicial action affecting the reporting company filing deadlines before the new extended filing deadlines arrive, we recommend that all reporting companies complete preparations to file their required BOI reports and assure that their BOI reports are properly filed by the relevant deadline.

If you have any questions about this, please contact Josh Kin, or your RCO Law professional for assistance.