Earlier this month, we reported that the U.S. District Court for the Eastern District of Texas issued a preliminary injunction staying the enforcement of the Corporate Transparency Act (CTA) and its Reporting Rule. This week the Federal Court of Appeals for the 5th Circuit decided that reporting companies are required to file their beneficial ownership information with FinCEN.

The Appellate Court decision was issued in the case of Texas Top Cop Shop, Inc. v Garland (E.D. Texas, No. 4:24-cv-00478; December 3, 2024). The Department of the Treasury has recognized that reporting companies may require additional time to comply with the CTA Beneficial Ownership Information reporting requirements and has extended the deadline for Beneficial Ownership Information Reporting | FinCEN.gov reporting from January 1, 2025 to January 13, 2025 for most companies.

Our Firm continues to file the Beneficial Ownership Information reporting for clients. For more information or to discuss any questions you may have concerning your company and the CTA, please contact Joan Berg at [email protected] or call 312-648-2300.

Effective January 1, 2024, the CTA became a federal law affecting all corporations, limited liability companies, limited partnerships and other entities registered with the Secretary of State of the state of formation. The CTA requires all reporting entities to register their beneficial ownership with the Financial Crimes Enforcement Network (FinCEN) database before the end of this year. FinCEN is a bureau of the United States Department of the Treasury that collects and analyzes information about financial transactions in order to combat domestic and international money laundering, terrorist financing, and other financial crimes.