Corporate Transparency Act Update: Reporting Obligations Reinstated

The rollercoaster that is the Corporate Transparency Act ("CTA") continues. In short, Reporting Companies (as defined by the CTA) are once again required to file beneficial ownership information reports ("BOIRs") with the U.S. Treasury's Financial Crimes Enforcement Network ("FinCEN"), and FinCEN has extended the reporting deadline to March 21, 2025, for the majority of Reporting Companies. However, Reporting Companies that were previously given a later deadline should abide by such later deadline to file their initial BOIRs (e.g., Reporting Companies that qualify for a disaster relief extension).

Background

As we initially reported, the CTA took effect on January 1, 2024, requiring Reporting Companies to file BOIRs with FinCEN. However, following legal challenges in the U.S. District Court for the Eastern District of Texas, the CTA was put on hold following two separate nationwide injunctions arising out of Texas Top Cop Shop, Inc. v. McHenry and Smith v. U.S.