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2024-12-24 CTA Update

CTA Reporting Obligation Reinstated by Appeals Court

On December 23, 2024, the U.S. Court of Appeals for the Fifth Circuit reinstated beneficial ownership reporting obligations under the Corporate Transparency Act and its implementing regulations (together, the “CTA”). 

Previously we reported that on December 3, 2024, the U.S. District Court in Texas court issued an injunction that stopped the enforcement of the CTA that requires all companies except those that fall within 23 different exceptions, to report specific information on their beneficial owners to the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”).

The decision on the 23rd nullifies the Texas court’s injunction and reinstates the CTA requirements.

Considering this decision, FinCEN issued a statement extending beneficial ownership information reporting deadlines, which we have noted in detail below. 

Just know that if your LLC or Corporation was created before January 1, 2024, and no exception applies you should report your beneficial ownership information to FINCEN by January 13, 2025. 

If, on the other hand, your entity was created on or after January 1, 2024, you must refer to the table below to find out your deadline.

Date of Creation or First RegistrationInitial Reporting Deadline
Before Jan. 1, 2024Jan. 13, 2025
Jan. 1, 2024 – Sept. 3, 2024Within 90 days of notice of creation or registration
Sept. 4, 2024 – Sept. 24, 2024Jan. 13, 2025
Sept. 25, 2024 – Dec. 2, 2024Within 90 days of notice of creation or registration
Dec. 3, 2024 – Dec. 23, 2024Additional 21 days from original filing deadline (i.e., within 111 days of notice of creation or registration)
Dec. 24, 2024 – Dec. 31, 2024Within 90 days of notice of creation or registration
On or after Jan. 1, 2025Within 30 days of notice of creation or registration

See our initial CTA blog and its impact on construction companies HERE

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This article is informational only and meant to provide guidance. It is not meant to be legal advice and it does not create an attorney-client relationship. For what to do in your specific situation, please consult with a qualified Construction Law attorney.

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