On Dec. 23, 2024, the U.S. Court of Appeals for the Fifth Circuit granted a stay of the injunction issued earlier this month that halted enforcement of the Corporate Transparency Act (CTA) and its Beneficial Ownership Information Reporting Rule. The stay by the Court of Appeals restored the initial CTA filing deadline for companies formed before 2024 of Jan. 1, 2025.

Following the stay, the Financial Crimes Enforcement Network (FinCEN) issued an alert extending the reporting rule’s initial deadlines to Jan. 13, 2025.

CTA BOI Report Deadlines Back in Effect

According to the FinCEN alert, the reporting deadline has been extended as follows:

• Reporting companies that were created or registered prior to Jan. 1, 2024, have until Jan. 13, 2025, to file their initial beneficial ownership information (BOI) reports with FinCEN. (These companies would otherwise have been required to report by Jan. 1, 2025.)
• Reporting companies created or registered in the United States on or after Sept. 4, 2024, that had a filing deadline between Dec. 3, 2024, and Dec. 23, 2024, have until Jan. 13, 2025, to file their initial beneficial ownership information reports with FinCEN.
• Reporting companies created or registered in the United States on or after Dec. 3, 2024, and on or before Dec. 23, 2024, have an additional 21 days from their original filing deadline to file their initial beneficial ownership information reports with FinCEN.