Last night, the Fifth Circuit Court of Appeals overturned the recent nationwide injunction of the Corporate Transparency Act (“CTA”) which temporarily paused filing obligations of reporting companies.  Put simply, the filing obligations of reporting companies have returned.  FinCen, recognizing the challenges this most recent turn of events has caused, has extended many reporting deadlines.  

WHAT YOU NEED TO KNOW: 

  • The initial filing deadline for companies formed on or before January 1, 2024, is January 13, 2025. 
  • The initial filing deadline for companies formed on and after September 4, 2024, is January 13, 2025.  
  • The initial filing deadline for companies formed on and after December 3, 2024, and on or before December 23, 2024, is 111 days from formation. 
  • The initial filing deadline for companies formed on and after December 24, 2024, and on or before December 31, 2024, is 90 days from formation.
  • The initial filing deadline for companies formed on and after January 1, 2025, is 30 days from formation.  
  • All companies remain obligated to update their reporting when previously filed information (for example, the address of a beneficial owner) changes.  The deadline to complete such update is 30 days from the change.  

This matter continues to be actively litigated.  Moreover, Congress is beginning to see the introduction of bills, such as the “Repealing Big Brother Overreach Act” (RBBOA), designed to overturn the CTA. While the ongoing litigation and legislative action could impact the future of the CTA, the current best practice is to adhere to the deadlines identified above.  

As always, Carmody will continue to keep you informed of changes.    

If you have any questions, do not hesitate to contact a member of our Corporate & Business Services team.

Stephanie E. Cummings
Partner
scummings@carmodylaw.com
203.575.2649

Matthew H. Gaul
Partner
mgaul@carmodylaw.com
203.784.3106

This information is for educational purposes only to provide general information and a general understanding of the law. It does not constitute legal advice and does not establish any attorney-client relationship.