On December 23, 2024, a federal appeals court overturned a lower district court's preliminary injunction that had paused the enforceability of the Corporate Transparency Act (CTA). The federal appeals court granted the federal government's motion to stay the injunction pending appeal resulting in the reinstatement of the CTA and its filing deadlines.
On that same date, the U.S. Treasury Department's Financial Crimes Enforcement Network (FinCEN) issued the following alert modestly extending the CTA's reporting deadline for certain companies:
"Reporting companies that were created or registered prior to January 1, 2024 have until January 13, 2025 to file their initial beneficial ownership information reports with FinCEN. (These companies would otherwise have been required to report by January 1, 2025.)"
In light of these developments, companies should continue preparations to comply with the CTA by the January 13, 2025 deadline.1
Congress passed the CTA as part of an anti-money laundering package in the 2021 National Defense Authorization Act, with the aim of curbing illicit financial activities, like tax evasion, money laundering, drug trafficking and terrorist financing. As described in our prior newsletters on December 9, 2024, August 9, 2024 and December 1, 2023, under the CTA, many corporations, limited liability companies, limited partnerships and similar legal entities are required to report ownership and management information (known as beneficial ownership information, or BOI) to FinCEN.
For additional information relating to the CTA, visit FinCEN's BOI web page.
Footnote
1 Reporting companies created on or after December 4, 2024, and on or before December 23, 2024, have an additional 21 days from their original filing deadline to file.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
