Client Alert: Corporate Transparency Act Compliance Deadline REINSTATED Following New Court Ruling

Client Alerts / December 2024

The Corporate Transparency Act (CTA) is back in effect following a ruling by the United States Court of Appeals for the Fifth Circuit.

Business owners should prepare to meet the new compliance deadline if they have not filed their Beneficial Ownership Information Reports (BOIR) already.

If you have previously provided us with your information to file your BOIR on your behalf, we will proceed with filing as planned to ensure compliance with the reinstated deadlines listed below. We will reach out if we require any additional information or updates regarding your filing.

Updated Compliance Deadlines

  • Reporting companies created or registered prior to January 1, 2024, now have until January 13, 2025, to file their initial BOI reports with FinCEN. (These companies were previously required to report by January 1, 2025.)
  • Reporting companies created or registered in the United States on or after September 4, 2024, that had a filing deadline between December 3, 2024, and December 23, 2024, now have until January 13, 2025, to file their initial BOI reports with FinCEN.
  • Reporting companies created or registered in the United States on or after December 3, 2024, and on or before December 23, 2024, have an additional 21 days from their original filing deadline to file their initial BOI reports with FinCEN.

Please note, additional lawsuits challenging the CTA are pending in other federal courts, which could further affect enforcement timelines.