by Kent A. Brasseale, II and Heather M. Lobermann
On December 4, 2024, we informed you of the nationwide injunction granted by the United States District Court for the Eastern District of Texas in Texas Top Cop Shop v. Garland et al. As discussed in that blog (https://kddk.com/2024/12/04/corporate-transparency-act-and-reporting-rule-enjoined-nationwide/), this nationwide injunction merely put the requirements on hold.
Now, this injunction has been stayed (or put on hold) pending resolution of the Department of the Treasury’s appeal in the federal courts. This means that essentially all “reporting companies” as defined under the Corporate Transparency Act (“CTA”) are again required to file the Beneficial Ownership Information Report with the Financial Crimes Enforcement Network of the Department of the Treasury. For more information on the CTA, please see our prior blog at https://kddk.com/2024/01/25/corporate-transparency-act-what-your-business-needs-to-know/.
When Is the Beneficial Ownership Information Report Due for Your Company?
- Companies existing prior to January 1, 2024: The filing deadline is now January 13, 2025.
- Entities with an initial deadline of December 3, 2024 through December 23, 2024: The filing deadline is now January 13, 2025.
- For entities created December 3, 2024 through December 23, 2024: The filing deadline is now 21 days after the initial filing deadline. This means that the filing deadline is 111 days after the formation of the entity with the State.
- Entities granted extensions due to disaster relief: The filing deadline is now the later of that extended deadline or January 13, 2025.
- Entities formed December 24, 2024 through December 31, 2024: The filing deadline should be 90 days after the formation of the entity with the State.
- Entities formed on January 1, 2025 and beyond: The filing deadline shall be 30 days after the formation of the entity with the State.
How Can KDDK Help My Entity Comply
If we can be of assistance with any questions you have regarding the CTA, please contact attorneys Kent (“KAB”) Brasseale, II at kbrasseale@kddk.com or Heather Lobermann at hlobermann@kddk.com, or by phone at (812) 423-3183.
