On December 23, 2024, the Fifth Circuit Court of Appeals stayed the injunction, meaning that the injunction is no longer in effect, and the Financial Crimes Enforcement Network of the U.S. Department of Treasury (FinCEN) may again enforce the CTA. 

As of this writing, FinCEN has not extended any filing deadlines. Therefore, all reporting companies should file any beneficial ownership information reports (BOIRs) that were already due and reporting companies formed prior to 2024 should file their BOIRs by January 1, 2025. 

Further to the ups and downs of implementing the Corporate Transparency Act (commonly the "CTA"), the latest announcement and current position is an extended deadline to January 13, 2025 (unless a further deadline is permitted in limited situations, such as with hurricane relief).  Late on December 23, 2024, FinCEN announced that Reporting Companies created or registered prior to January 1, 2024 generally have until January 13, 2025 to file their initial BOI reports with FinCEN.   More and complete information is available at: https://www.fincen.gov/boi, which in relevant part states:



While an early version of a proposed "continuing resolution" in the US Congress (a "CR" to continue funding the U.S. government) would have extended the January 1, 2025 date by a year, this proposed extension was dropped from the CR funding bill that was ultimately approved and signed into law, so had no effect on the CTA deadline.  We continue to closely monitor these developments and recommend that all owners and managers of potential reporting companies do the same.