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Update: CTA Filing Extended to January 13, 2025 for Entities Formed Prior to 2024

on Tuesday, 24 December 2024 in Banking Update

On the evening of December 23, 2024 the Department of Treasury announced that companies that were created or registered prior to January 1, 2024 and are not otherwise exempt under the Corporate Transparency Act (CTA) from filing a beneficial ownership information report (BOIR) with FINCEN now have until January 13, 2025 to file their BOIR. These companies would otherwise have been required to report by January 1, 2025.

This announcement was made as a result of the Fifth Circuit Court of Appeals issuing an order earlier in the day on December 23 which lifted the nationwide preliminary injunction that was previously issued by a federal district court in Texas on December 3, 2024 to suspend enforcement of CTA reporting obligations.  The appellate ruling failed to extend the January 1 BOIR reporting deadline so the Department of Treasury extended the January 1 deadline to January 13, 2025 for those entities formed prior to January 1, 2024.

For entities formed during 2024 which are not otherwise exempt from BOIR filing requirements the applicable deadline for filing varies based on the date of formation during 2024. Here is a link to the official announcement form the Department of Treasury which provides further information:  https://www.fincen.gov/boi

For further background information on the CTA please see our previously published articles – The Corporate Transparency Act – What You Need to Know Now, Your Health Care Organization Could Be Subject to the Corporate Transparency Act (CTA), What is Happening with the Corporate Transparency ACT (CTA)?, and Well, That was Quick – The Corporate Transparency Act is Back: Appellate Court Lifts Nationwide Injunction

The contents of this Client Alert are for informational purposes only and do not constitute legal advice. If you have any questions or want to engage our Firm to provide CTA compliance services, please contact a Baird Holm attorney.

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