On December 23, 2024 the United States Court of Appeals for the Fifth Circuit granted the federal government’s effort to put the Corporate Transparency Act (CTA) back into effect nationwide. The filing deadlines for beneficial ownership information reports have been restored with brief extensions as described in detail below, including a January 13, 2025 (instead of January 1) deadline for
reporting companies created before January 1, 2024.
As we previously reported, on December 3, 2024, a federal district court in Texas issued a nationwide preliminary injunction against the
enforcement of the CTA and the Financial Crimes Enforcement Network’s (FinCEN) final rule imposing reporting requirements of
beneficial ownership information.
The district court blocked enforcement of the law nationwide, suspending the reporting deadlines. On December 13, the government
moved for a stay pending appeal, asking the Fifth Circuit to allow the reporting requirements to go immediately into effect. The Fifth Circuit has now granted the government’s motion for a stay.
Reporting is once again required nationwide, subject to the modified deadlines in this alert.