GrayRobinson Business Law Insight: Corporate Transparency Act Updated Filing Deadlines

December 26, 2024

By: Kevin Levy and Natali Reyes

On December 23, 2024, the Fifth Circuit Court of Appeals granted the federal government’s request for a stay of the nationwide injunction previously issued by a Texas court, which had temporarily prevented enforcement of the Corporate Transparency Act (CTA).

As a result, the Financial Crimes Enforcement Network (FinCEN) may now resume enforcing the CTA. Below is an updated timeline for filing initial Beneficial Ownership Information (BOI) reports pursuant to the CTA:

  1. Pre-2024 Reporting Companies: Companies created or registered before January 1, 2024 must file their initial BOI reports on or before January 13, 2025.
     
  2. September-December 2024 Filings: Companies created or registered between September 4, 2024 and December 2, 2024, with original filing deadlines between December 3, 2024, and December 23, 2024, now have until January 13, 2025, to comply.
     
  3. December 2024 Filings: Companies created or registered between December 3, 2024 and December 23, 2024 are granted an additional 21 days from their original deadlines to submit BOI reports.
     
  4. Disaster Relief Extensions: Reporting companies eligible for disaster relief may have extended deadlines that exceed January 13, 2025. Such companies should comply with the later applicable deadline. Please Note - A six-month extension remains in effect for companies in designated counties impacted by hurricanes earlier this year. More details can be found at: FinCEN Provides Beneficial Ownership Information Reporting Relief to Victims of Hurricane Milton; Certain Filing Deadlines in Affected Areas Extended Six Months.
     
  5. Post-January 2025 Filings: Companies created or registered on or after January 1, 2025 must file BOI reports within 30 days of receiving actual or public notice that their creation or registration is effective.

For additional background, please also review our prior Insights titled “Texas Court Issues Preliminary Injunction Blocking Enforcement of the Corporate Transparency Act Nationwide,” “Corporate Transparency Act Filing Deadlines Extended for Hurricane Victims,” “Corporate Transparency Act Filing Deadline Fast Approaching for Pre-existing Companies,” and “Corporate Transparency Act and the End of Hiding in the U.S."

Questions?
Contact GrayRobinson Business Law Section Chair Kevin Levy, Attorney Natali Reyes, or a member of the Business Law Section.

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