Corporate Transparency Act – Nationwide Injunction Lifted – New January 13 Deadline in Force
On December 23, 2024, the Fifth Circuit Court of Appeals granted the U.S. government’s request to lift the nationwide injunction preventing enforcement of the Corporate Transparency Act. As a result, all reporting entities are again required to file Beneficial Ownership Information reports (“BOIRs”). However, the Department of the Treasury has extended certain deadlines to file BOIRs. If you have not yet filed your BOIRs for reporting entities created prior to January 1, 2024, you must file your BOIRs before January 13, 2025 to be compliant with the Corporate Transparency Act. For any reporting entities registered or created during the period of time while the nationwide injunction was in effect (December 3, 2024 to December 23, 2024), you have an additional 21 days from the original filing deadline for that reporting entity to file an initial BOIR.
For more information on who is required to report and what entities may be exempt, please see our client alert: Corporate Transparency Act Compliance Reminder and Guidance.
Please contact one of the Shartsis Friese attorneys in the Investment Funds & Advisers Group if you have questions about your reporting obligations in light of the imminent filing deadline.
Previous letters to our investment advisory clients and friends and discussions of other topics relevant to private fund managers, investment advisers and private investment funds can be found at our insights page: www.sflaw.com/blog/investment-funds-advisers-insights.