CTA Reporting Requirements Back in Effect – New Filing Deadline January 13, 2025

On December 23, 2024, the U.S. Court of Appeals for the Fifth Circuit granted a stay of the district court’s preliminary injunction in Texas Top Cop Shop, Inc., et al.  v. Garland, et al. As a result, the requirement to file Beneficial Ownership Information (BOI) under the Corporate Transparency Act (CTA) is back in effect until the Department of the Treasury’s appeal is resolved. For information on the prior suspension of the CTA, see our prior alert HERE.

The Financial Crimes Enforcement Network (FinCEN) has extended some relief by shifting the compliance deadline for certain filings from January 1, 2025, to January 13, 2025. Millions of small businesses and corporate entities across the U.S. must act quickly to comply with the CTA requirements to avoid significant penalties.

What Does This Mean for Your Business?

Given the significant consequences involved, businesses must move quickly to ensure compliance.

• Entities created before January 1, 2024, now have until January 13, 2025, to file their initial BOI reports.
• Entities created 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 BOI reports.
• Entities created on or after December 3, 2024 and on or before December 23, 2024 have an additional 21 days from their original filing deadlines to file their initial BOI reports.
• Entities formed after January 1, 2025, must file within 30 days.

If you have questions or need assistance navigating these requirements and filing before the new deadline, contact Jason Lederman at jlederman@steinadlerlaw.com or 917.639.5121.