On December 23, 2024, the U.S. Court of Appeals for the Fifth Circuit issued a decision affecting the Corporate Transparency Act (CTA), reinstating the requirement for most reporting companies to file beneficial ownership information with the Financial Crimes Enforcement Network (FinCEN). This ruling follows a stay of a nationwide preliminary injunction issued earlier on December 3, 2025 by the U.S. District Court for the Eastern District of Texas. The CTA continues to face legal challenges in several courts across the country, but, as of now, remains the law of the land.

To see whether your business might be a “reporting company,” visit our prior client alert summarizing the scope of the CTA.

New Filing Deadlines for Reporting Companies

The Department of the Treasury has extended the filing deadlines for some reporting companies. Below are the updated deadlines:

1. Reporting Companies Created or Registered Prior to January 1, 2024:

    • These companies must file their initial beneficial ownership information reports with FinCEN by January 13, 2025. This represents an extension from the original January 1, 2025 deadline.

2. Reporting Companies Created or Registered Between January 1, 2024 and September 3, 2024:

    • These companies’ reporting deadlines passed during the period prior to the December 3, 2025 preliminary injunction, which stayed enforcement of the CTA. As such, these companies are out of compliance and should file their reports immediately.

3. Reporting Companies Created or Registered Between September 4, 2024 and September 23, 2024:

    • These companies now have until January 13, 2025 to submit their reports.

4. Reporting Companies Created or Registered Between September 24, 2024 and December 2, 2024:

    • These companies have no changes to their reporting deadline, meaning they must file their reports within 90 days of receiving notice of their creation or registration.

5. Reporting Companies Created or Registered between December 3, 2024 and December 23, 2024:

    • These companies are granted an additional 21 days from their original filing deadline to file their initial beneficial ownership information reports with FinCEN, meaning they must file their reports within 111 days of receiving notice of their creation or registration.

6. Reporting Companies Created or Registered Between December 24, 2024 and December 31, 2024:

    • These companies have no changes to their reporting deadline, meaning they must file their reports within 90 days of receiving notice of their creation or registration.

7. Reporting Companies Created or Registered On or After January 1, 2025:

    • These companies must file their reports within 30 days of receiving notice of their creation or registration.

Filing and Staying Informed

Reporting companies can submit their beneficial ownership reports through the FinCEN Online Filing System: https://boiefiling.fincen.gov/fileboir

If you have questions or need legal guidance to ensure compliance with the CTA, our law firm is here to help. Contact your FGKS attorney today.

Original Publish Date: December 26, 2024

Recent Posts