Corporate Transparency Act – Update: December 23, 2024

5^th Circuit Appeals Court Issues Temporary Stay of Preliminary Injunction.

On December 23, 2024, the US Court of Appeals for the 5^th Circuit issued a temporary stay of the preliminary injunction enjoining the CTA and its corresponding reporting rule. https://fingfx.thomsonreuters.com/gfx/legaldocs/zjpqnmamxvx/12232024cta.pdf

In effect, this latest decision reinstates the Beneficial Ownership Information reporting requirements.  Deadlines for filing of the initial BOI report have been adjusted as follows:

1. Reporting Companies created prior to January 1, 2024 have until January 13, 2025 to file their initial BOI report
2. Reporting Companies created on or after September 4, 2024 have until January 13, 2025 to file their initial BOI report.
3. Reporting Companies created on or after December 3, 2024 and before December 23, 2024 have 90 days plus an additional 21 days from the original filing deadline to file their initial BOI report.
4. Reporting Companies with a filing deadline after January 13, 2025 should abide by their current applicable deadlines
5. Reporting Companies formed on or after January 1, 2025 have 30 days to file their initial BOI report.

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