On December 3, 2024, a federal district court in Texas issued a nationwide injunction that enjoined the federal government from enforcing the Corporate Transparency Act (“CTA”). Pursuant to that injunction, reporting companies nationwide were not required to comply with the CTA’s January 1, 2025, deadline.
However, on December 23, 2024, the U.S. Court of Appeals for the 5th Circuit issued an order staying the district court’s nationwide preliminary injunction pending appeal. In effect, this means that the CTA’s January 1, 2025, deadline for reporting companies has been reinstated.
Nevertheless, the Financial Crimes Enforcement Network (the agency administering the CTA) has issued guidance extending the deadline for filing beneficial ownership for certain entities beyond the January 1, 2025, deadline. The specific deadline depends on when the reporting company was formed. Please see the chart below for the new deadlines.
Date Reporting Company was Formed or Registered | Deadline |
Prior to January 1, 2024
|
January 13, 2025 |
On or after September 4, 2024, such that the original filing deadline was between December 3, 2024, and December 23, 2024
|
January 13, 2025 |
On or after December 3, 2024, and on or before December 23, 2024
|
Additional 21 days from original filing deadline |
January 1, 2025, and after
|
Within 30 days of formation |
The situation regarding the CTA is rapidly evolving. Woods Aitken will continue to monitor updates and provide additional information as it becomes available. For general information regarding the CTA, please see our previous E-Brief here.
If you have any specific questions, please do not hesitate to reach out to your contact at Woods Aitken, or one of the following:
William A. Ozaki (Lincoln): wozaki@woodsaitken.com or (402) 817-4860
Daniel R. Carnahan (Omaha): dcarnahan@woodsaitken.com or (402) 898-7430
Lena A. Lucas (Denver): llucas@woodsaitken.com or (303) 606-6707