The Fifth Circuit has reinstated the Corporate Transparency Act (CTA) filing requirements, with most entities required to file by January 1, 2025, unless exempt or already filed.
However, several updates and extensions may affect your filing deadline:
1. Florida Entities in Disaster Zones:
Most entities in Florida may qualify for a six-month extension due to disaster relief for areas impacted by hurricanes Debby, Helene, and Milton. If your entity is located in a federally recognized disaster zone, this extension likely applies to you.
2. Revised Filing Deadlines from FinCEN:
Following the December 23, 2024, federal Court of Appeals decision, the Department of the Treasury has provided the following adjustments:
– Reporting Companies Created/Registered Before January 1, 2024: Deadline extended to January 13, 2025.
– Reporting Companies Created/Registered Between September 4, 2024, and December 23, 2024:
– If your original deadline fell between December 3 and December 23, 2024, you now have until January 13, 2025.
– Companies registered during this period have an additional 21 days from their original deadline.
– Entities Created/Registered On or After January 1, 2025: Must file within 30 days of creation or registration notice.
This situation remains fluid. We anticipate additional commentary and possibly further interventions from higher courts, which could result in further changes. While this is the current status, we strongly recommend staying prepared and keeping informed of updates.
If you have questions or need assistance with your specific filing obligations, please don’t hesitate to reach out.
We recommend leveraging USRA for these services, given their experience in regulatory compliance. To initiate the process, simply click the link below: