Reporting companies are once again required to comply with the Corporate Transparency Act (CTA) beneficial ownership information (BOI) reporting requirements, although the deadline has been shifted slightly to allow those companies required to report more time. A federal court in a challenge to the CTA, Texas Top Cop Shop, Inc. v. Garland, et al., had temporarily halted enforcement, but on December 23, 2024, the U.S. Court of Appeals for the Fifth Circuit overturned that injunction.

The new reporting deadlines are as follows:

• Companies created or registered before January 1, 2024: The initial BOI report deadline has been extended from January 1, 2025, to January 13, 2025.
• Companies created or registered on or after September 4, 2024: Companies with a filing deadline falling between December 3, 2024, and December 23, 2024, now have until January 13, 2025, to submit their BOI reports.
• Companies created or registered between December 3, 2024, and December 23, 2024: These companies are granted an additional 21 days from their original filing deadline to submit BOI reports.
• Companies created or registered on or after January 1, 2025: These companies must file their BOI reports within 30 days of receiving actual or public notice of their creation or registration.
• Companies qualifying for disaster relief: Extended deadlines may apply if they fall beyond January 13, 2025. These companies should adhere to whichever deadline occurs later.

Here is what we recommend for those obligated to report:

• Prepare to File by January 13, 2025, as time is of the essence. Businesses that have not yet filed their BOI reports should ensure that all information has been gathered and that the BOI report is prepared for submissions well before the new deadline of January 13, 2025.
• Companies formed after December 3, 2024, should consult with their legal counsel to confirm their specific filing deadline. The filing deadline may differ for reporting companies, so please reach out to our team for further information.

All businesses should remain informed of all pending legal challenges to the CTA that remain unresolved. This case is just one of the several that remains pending and addresses the CTA’s constitutionality. Therefore, additional developments are likely forthcoming that may impact compliance obligations in the near future.

If you have any questions about this FinCEN release or the new filing deadline for your company, please reach out to a Procopio Corporate or Tax attorney for additional information.