Important Update Part 2: Corporate Transparency Act & Beneficial Ownership Filings

In December 2024, we wrote a blog post regarding the Corporate Transparency Act (CTA).  A federal district court in Texas had issued a nationwide injunction blocking enforcement of the CTA’s reporting requirements. This injunction has now been overturned on appeal.

This means that the CTA’s beneficial ownership reporting requirements are once again in effect. As outlined in our January 2024 blog post, these requirements apply to many businesses—including corporations, limited liability companies, and other entities created by state filings—which must report information about their beneficial owners to the Financial Crimes Enforcement Network (FinCEN).

Given this development, affected businesses should take immediate steps to comply with the reporting requirements:

1.  Companies formed before January 1, 2024, must file their initial reports by January 13, 2025
2.  Companies formed in 2024 must file within 90 days of formation
3.  Companies formed in 2025 or later must file within 30 days of formation

If you have maintained records as we previously recommended, you should be well-positioned to complete the required filings. If you have questions about whether these requirements apply to your business or need assistance with compliance, we encourage you to contact our office to schedule a consultation.

We will continue to monitor any further developments regarding the CTA and provide updates as warranted.