Alert

Dec 26, 2024

Fifth Circuit Lifts Injunction on Corporate Transparency Act: New Reporting Deadlines Announced

On December 23, 2024, the United States Court of Appeals for the Fifth Circuit issued an order granting the Department of Justice’s emergency motion for a stay pending appeal, lifting the nationwide injunction blocking the government from enforcing the reporting requirements of the Corporate Transparency Act (“CTA”).  

Enacted to combat money laundering, financing of terrorism and serious tax fraud, the CTA requires certain businesses to report information about their ownership to the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”). In conjunction with the order reinstating the CTA, FinCEN extended the deadlines by which businesses must report their beneficial ownership:

• Businesses in existence prior to January 1, 2024, have until January 13, 2025, to report.
• Businesses 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 report.
• Businesses created on or between December 3, 2024, and December 23, 2024, have an additional twenty-one (21) from their original filing deadline to report.
• Businesses qualifying for disaster relief, which may have a deadline falling beyond January 13, 2025, should abide by the later filing deadline. 

Please reach out to any of the Roetzel corporate attorneys or your regular Roetzel counsel with any questions, or if you would like assistance filing your beneficial ownership report.