Insights
Corporate Transparency Act Enforcement Paused Again – Here’s What You Need to Know
The required December 31, 2024 compliance deadline for the Corporate Transparency Act (CTA) has been influx again this week. Here is a timeline and where compliance with the CTA is as of today, December 31, 2024:
- December 3, 2024: The Federal District Court for the Eastern District of Texas issued a preliminary injunction against the enforcement of the CTA’s beneficial ownership reporting requirements, citing constitutional concerns.
- December 23, 2024: An order from the Federal Fifth Circuit Court of Appeals essentially lifted the preliminary injunction. Shortly after this ruling, new deadlines were announced for businesses to report beneficial ownership information to the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN), including: (i) all entities in existence as of January 1, 2024 have a deadline of January 13, 2025; (ii) entities created between December 3, 2024 and December 23, 3024 have an additional twenty one (21) days added to their existing ninety (90) day filing period; (iii) any entities qualifying for disaster relief will continue to have those applicable disaster relief rules; and (iv) any entities filed after January 1, 2025 will have thirty (30) days to file their beneficial interest report.
- December 26, 2024: A separate panel of the Federal Fifth Circuit Court of Appeals reinstates the preliminary injunction while the Court considers the government’s appeal. This decision once again halts the enforcement of the CTA requirements of reporting beneficial ownership interest to FinCEN.
Please note that in certain areas of Florida the extensions granted due to Hurricane Milton remains in effect. For those entities in a designated FEMA disaster zone because of Hurricane Milton, the following applies:
- Existing Entities (formed before 2024):
- Original Deadline: January 1, 2025
- New Deadline with Extension: July 1, 2025
- New Entities (formed in 2024 or later):
- Original Deadline: Ninety (90) days following the entity’s formation
- New Deadline with Extension: If your entity’s beneficial ownership information report deadline falls between October 4, 2024, and January 2, 2025, there is an additional six (6) months added to original filing deadline.
If you have any questions regarding where your business’ filing requirements currently stand, please contact our office at 941-748-0100.
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