Following our previous update on December 8, 2024, we wish to update you about an important development regarding the Corporate Transparency Act (CTA).
On December 23, 2024, the U.S. Fifth Circuit Court of Appeals lifted a temporary nationwide injunction on the enforcement of the Corporate Transparency Act (CTA). As a result, the Beneficial Ownership Information (BOI) reporting requirements and deadlines are once again effective. In response to the December 23rd decision, enable reporting companies to meet the submission’s deadline and compensate for the time when the preliminary injunction had been in effect, FinCEN has announced that it is granting a short extension to the filing deadline for certain companies, as follows:
- Reporting companies that were created or registered prior to January 1, 2024: reports must now be filed by January 13, 2025 (previously January 1, 2025).
- Reporting companies that were created or registered on or after September 4, 2024 that had a filing’s deadline between December 3, 2024, and December 23, 2024: reports are due by January 13, 2025.
- Reporting companies that were created or registered between December 3, 2024, and December 23, 2024: an additional 21 days have been granted from their original filing’s deadline.
While compliance deadlines are now back in effect, the Fifth Circuit’s decision does not conclude the ongoing litigation surrounding the CTA’s constitutionality.
We strongly recommend prioritizing the preparation of BOI reports to ensure compliance with the reinstated deadlines.
We will continue to monitor this matter closely and will provide you with updates as the situation evolves.
This document is intended to provide only a general background regarding this matter.
This document should not be regarded as setting out binding legal advice but rather as a practical overview that is based on our understanding. APM & Co. is not licensed to practice law outside of Israel.
Contact Us
For assistance navigating the CTA, please feel free to contact your designated contact person at our office or reach out directly to Dr. Tal Tirosh at talt@apm.law. We would be delighted to assist you.
