On December 23, 2024 FinCEN announced that in light of a federal Court of Appeals decision issued that day granting a stay of the preliminary injunction enjoining the Corporate Transparency Act (CTA) entered in the case of Texas Top Cop Shop, Inc. v. Garland, pending the outcome of the Department of the Treasury’s ongoing appeal of the district court’s order, that reporting companies are once again required to file beneficial ownership information reports (BOIR) with FinCEN.
FinCEN also announced that because the Department of the Treasury recognizes that reporting companies may need additional time to comply given the period when the preliminary injunction had been in effect, they are extending the reporting deadlines as follows:
- Reporting companies that were created or registered before to January 1, 2024 have until January 13, 2025 to file their initial BOIR.
- Reporting companies created or registered 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 file their initial BOIR.
- 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 their initial BOIR.
- Reporting companies that qualify for disaster relief may have extended deadlines that fall beyond January 13, 2025. These companies should abide by whichever deadline falls later.
- Reporting companies that are created or registered on or after January 1, 2025 have 30 days to file their initial BOIR after receiving actual or public notice that their creation or registration is effective.
