This alert provides an update on recent developments regarding the Corporate Transparency Act (“CTA”) and associated filing deadlines. As detailed in this prior alert, earlier this month, a federal district court issued a nationwide preliminary injunction halting the enforcement of the CTA. The Financial Crimes Enforcement Network (“FinCEN”) had indicated that reporting companies were not obligated to file their Beneficial Ownership Information Reports (“BOIR”) while the injunction was in place. The federal government promptly appealed this decision.
On December 23, 2024, the Fifth Circuit Court of Appeals issued an order granting the federal government’s motion to stay the injunction pending appeal. As a result, the deadline for reporting companies to submit their initial BOIR is reinstated pending further proceedings, with brief extensions as indicated in the chart below. In general, FinCEN has extended the January 1, 2025 deadline for filing an initial BOIR to January 13, 2025.
The following are details of the revised deadlines for filing an initial BOIR under the CTA:
| Reporting Company Creation/Registration Date | Extended Initial BOIR Filing Deadline |
| Prior to January 1, 2024 | January 13, 2025 |
| On or after September 4, 2024, with an original filing deadline between December 3, 2024, and December 23, 2024 | January 13, 2025 |
| On or after December 3, 2024, and on or before December 23, 2024 | An additional 21 days from the original filing deadline (90 calendar days from the company’s notice of creation or registration) |
| On or after December 24, 2024, and on or before December 31, 2024 | 90 calendar days from the company’s notice of creation or registration |
| On or after January 1, 2025 | 30 calendar days from the company’s notice of creation or registration |
Please ensure your compliance with these updated deadlines. If you have any questions or need assistance with filing, do not hesitate to contact us.