Corporate Transparency Act Filing Deadline Reinstated

What Happened?
On December 23, 2024, a federal appeals court reinstated the reporting requirements under the Corporate Transparency Act (CTA), lifting a previous nationwide injunction issued on December 3, 2024, that had blocked enforcement of the CTA. As a result, all reporting companies must now comply with the CTA’s reporting requirements.

What Are the Reporting Deadlines?
In response to the delays caused by the injunction, the Department of the Treasury has extended the reporting deadlines under the CTA:

• Companies formed or registered before January 1, 2024, must file their initial beneficial ownership information reports with FinCEN by January 13, 2025.
• Companies formed on or after September 4, 2024, that had a filing deadline between December 3, 2024, and December 23, 2024, have until January 13, 2025, to file their initial reports.
• Companies formed between December 3, 2024, and December 23, 2024, have an additional 21 days from their original filing deadline to submit their reports. Their original filing deadline was 90 days after formation.
• Companies formed on or after January 1, 2025, have 30 days to file their initial beneficial ownership information reports.

How is Bernstein Shur Helping Clients Comply with the CTA?
Our Business Law Practice Group has been closely monitoring the CTA since it was enacted and is ready to assist you. If you have any questions about whether or when you need to file a report, our interdisciplinary business law team is ready to help. Contact your Bernstein Shur attorney or Bryce Morrison at bmorrison@bernsteinshur.com.