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Update: US Corporate Transparency Act now back in effect with limited deadline extensions
A US federal appeals court has lifted an order blocking the nationwide enforcement of the US Corporate Transparency Act (CTA). (Please see our previous blog here.) The 23 December ruling allows the CTA to once again be enforced while the original case challenging the constitutionality of the CTA proceeds. The appeals court said that, in defending the CTA, the US Department of Justice "made a strong showing that it is likely to succeed on the merits in defending the CTA's constitutionality." In light of this ruling, reporting companies are once again required to file beneficial ownership reports with The US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN).
However, recognizing that reporting companies may need additional time to comply with their reporting requirements given the period when the preliminary injunction pausing enforcement of the CTA was in effect, FinCEN has extended the reporting deadlines for beneficial ownership reports as follows:
- Reporting companies that were created or registered prior to 1 January 2024 have until 13 January 2025 to file their initial beneficial ownership information reports with FinCEN. (These companies would otherwise have been required to report by 1 January 2025.)
- Reporting companies created or registered in the US on or after 4 September 2024 that had a filing deadline between 3 December 2024 and 23 December 2024 have until 13 January 2025 to file their initial beneficial ownership information reports with FinCEN.
- Reporting companies created or registered in the US on or after 3 December 2024 and on or before 23 December 2024 have an additional 21 days from their original filing deadline to file their initial beneficial ownership information reports with FinCEN.
- Reporting companies that are created or registered in the US on or after 1 January 2025 have 30 days to file their initial beneficial ownership information reports with FinCEN after receiving actual or public notice that their creation or registration is effective.