Corporate Transparency Act (CTA) Update
The United States Court of Appeals for the Fifth Circuit Lifts December 3, 2024 Injunction that blocked beneficial ownership interest reporting requirements.
On December 3, 2024, a Federal Court in Texas Top Cop Shop, Inc. v. Garland, E.D. Tex., No. 4:24-cv-00478, preliminarily blocked the CTA reporting requirements pending further order of court. However, on December 23, 2024, the federal appeals court for the Fifth Circuit lifted the injunction and Fin/Cen provided new reporting deadlines.
Previously, any business entity created prior to January 1, 2024, was required to file its Beneficial Ownership Interest Report (“BOIR”) by December 31, 2024. Now those entities have until January 13, 2025. Entities created after September 4, 2024 had ninety (90) days from formation to file their BOIR and now have until January 13, 2025. Also, entities created on or after December 3, 2024 (initial injunction), and before December 23, 2024 (lifting of injunction), the reporting deadline is extended 21 days from their original filing due date. Entities formed on or after January 1, 2025 will have 30 days from formation to file their BOIR.
We will continue to monitor the CTA and its BOIR requirements. If you have questions about the ever changing CTA compliance requirements, please reach out to Attorneys Daniel P. Lynch and Eric A. Thomas at (724) 776-8000.
