December 24, 2024 – As of December 23, 2024, the enforceability of the Corporate Transparency Act (CTA) has been reinstated (pending further appeals). The U.S. Treasury subsequently issued certain extensions.

The announced extensions for certain compliance deadlines, are as follows:

• Reporting companies that were created or registered prior to January 1, 2024 have until January 13, 2025 to file their initial beneficial ownership information reports with FinCEN. (These companies would otherwise have been required to report by January 1, 2025.)
• Reporting companies created or registered in the United States 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 beneficial ownership information reports with FinCEN.
• Reporting companies created or registered in the United States 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 beneficial ownership information reports with FinCEN.

On December 24, 2024, the Plaintiffs in Texas Top Cop Shop, Inc. v. Garland filed an emergency petition with the Fifth Circuit for en banc review of the panel’s decision to stay the lower court’s injunction. Plaintiffs have requested that a decision be made by January 6, 2025.

RRD will continue to monitor the situation as it develops. Please contact your RRD attorney with any questions.