On December 23, 2024, the Fifth Circuit Court of Appeals upheld the enforceability of the Corporate Transparency Act (the “CTA”). Reporting companies are once again required to file beneficial ownership information (“BOI”) reports.

The case is still being litigated; however, at this time, the requirement for businesses to file BOI reports is in effect. As a result of the ruling, the deadline for most reporting companies to file BOI reports has been extended to January 13, 2025. More specific deadlines may apply – please see additional details below:

• Reporting companies that were created or registered prior to January 1, 2024 have until January 13, 2025 to file their initial BOI reports (These companies would otherwise have been required to report by January 1, 2025.)
• Reporting companies created or registered on or after September 4, 2024 that had a filing deadline between December 3, 2024 and December 23, 2024 have until January 13, 2025 to file their initial BOI reports.
• Reporting companies created or registered on or after December 3, 2024 and on or before December 23, 2024 have an additional 21 days from their original filing deadline to file their initial BOI reports.
• Reporting companies that are created or registered on or after January 1, 2025 have 30 days after formation to file their initial BOI reports.

If you have any questions about CTA compliance in light of this update, please contact the GCT attorney with whom you work. GCT will continue to monitor developments and provide updates as they become available.