top of page
C. Richard Wilkins

UPDATE: FIFTH CIRCUIT COURT OF APPEALS LIFTS INJUNCTION ON BENEFICIAL OWNERSHIP INFORMATION REPORTING

On December 23, 2024, the Fifth Circuit Court of Appeals lifted the nationwide injunction issued on December 3, 2024 on enforcement of the Beneficial Ownership Information Report filing requirements under the Treasury Department’s Corporate Transparency Act.  Upon dissolution of that injunction, FinCEN issued an ALERT extending the reporting deadlines as follows:

 

  • Reporting companies that were created or registered prior to January 1, 2024 have until January 13, 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.

  • 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.

  • Reporting companies that qualify for disaster relief may have extended deadlines that fall beyond January 13, 2025. These companies should abide by whichever deadline falls later.

  • Reporting companies that are created or registered in the United States on or after January 1, 2025 have 30 days to file their initial beneficial ownership information reports with FinCEN after receiving actual or public notice that their creation or registration is effective.

6 views0 comments

Comments


bottom of page