On December 23, 2024, the Fifth Circuit Court of Appeals lifted the nationwide preliminary injunction in Texas Top Cop Shop, Inc., et al. v. Garland, et al., No. 4:24-cv-00478 (E.D. Tex.), which prohibited the federal government from enforcing the Corporate Transparency Act ("CTA"), and its regulations and reporting deadlines. The US Treasury Department's Financial Crimes Enforcement Network (FinCEN) has issued an alert that they have extended the initial reporting deadlines under the CTA as follows:
- Reporting companies created or registered prior to January 1, 2024, have until January 13, 2025 to file;
- Reporting companies created or registered on or after September 4, 2024, that have a filing deadline between December 3, 2024 and December 23, 2024 have until January 13, 2025 to file;
- Reporting companies created or registered on or after December 3, 2024 and on or before December 23, 2024 have an additional 21 days from their original filing deadline to file;
- Reporting companies that qualify for disaster relief may have extended deadlines that fall beyond January 13, 2025;
- Reporting companies that are created or registered after January 1, 2025 have 30 days to file after receiving actual or public notice that their creation or registration is effective.
Reporting companies should continue to monitor the litigation developments and guidance issued by FinCEN.
See, https://fincen.gov/boi, "Alert: Update to Beneficial Ownership Information Reporting Deadlines – Beneficial Ownership Information Reporting Requirements Now in Effect, with Deadline Extensions".