On December 23, 2024, the Fifth Circuit issued an order granting a stay of the December 3 nationwide injunction against the Corporate Transparency Act (CTA) that was originated in the U.S. District Court for the Eastern District of Texas. Effective immediately, the CTA’s beneficial ownership reporting requirements are reinstated, subject to deadline extensions below.

Following the ruling, FinCEN released a statement indicating that the original December 31, 2024, initial BOI report deadline has been extended to January 13, 2025, for reporting companies that were created or registered prior to January 1, 2024. Reporting companies that were created or registered on or after September 4, 2024, that had a reporting deadline between December 3 and December 23, 2024, also must file initial BOI reports by January 13, 2025. Reporting companies created or registered on or after December 3 and on or before December 23, 2024, will receive an additional 21 days from their original filing deadlines to file initial BOI reports with FinCEN. Importantly, companies created on or after January 1, 2025, will now have only 30 days from receiving actual or public notice to file initial BOI reports.

We will continue to monitor the developments in this arena for any further developments.