Corporate Transparency Act Response Team

UPDATE: A December 26, 2024 decision by a separate merits-panel of the Fifth Circuit Court of Appeals has lifted the stay of the preliminary injunction originally granted by the motions-panel of the Fifth Circuit on December 23, 2024. This decision halts compliance requirements for Reporting Companies under the Corporate Transparency Act, including the submission of Beneficial Ownership Information Reports (“BOIR”). Please see our latest alert for more information.

On January 1, 2021, Congress enacted the Corporate Transparency Act (“CTA”), which requires that certain companies disclose the identity of their beneficial owners and provide other information to the Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) beginning January 1, 2024 (the “Reporting Rule”). 

Under the Reporting Rule, entities classified as “Reporting Companies” which are formed during the calendar year 2024 must file Beneficial Ownership Information Reports (“BOIRs”) with FinCEN within 90 days of their formation. Reporting Companies formed on or after January 1, 2025 must file BOIRs within 30 days of their formation. Reporting Companies formed prior to January 1, 2024, will have until January 1, 2025 to file their BOIRs.

To determine if your company is a “reporting company” or if your company is exempt from the reporting requirements, please view FinCEN’s Small Business Compliance Guide for more information. FinCEN has also prepared Frequently Asked Questions (FAQs) in response to inquiries received relating to the Beneficial Ownership Information Reporting Rule.

Links to our news alerts about the CTA:

• Corporate Transparency Act – Halted Again Following New Fifth Circuit Decision
• Corporate Transparency Act’s Injunction Overturned – Deadline Extended Until January 13, 2025
• Texas Federal Court Halts Corporate Transparency Act Compliance Nationwide
• Corporate Transparency Act Update: FinCEN Updates Subsidiary Exemption Criteria
• Corporate Transparency Act Update: Dissolved Entities May Still Need to File Beneficial Ownership Reports 
• The Corporate Transparency Act’s Impact on HOAs and Condominium Associations
• The Corporate Transparency Act: What to Know About the Exemption for Large Operating Companies
• FinCEN Issues Proposed Deadline Extension for Certain Companies to File Beneficial Ownership Information Reports, Provides Further Guidance
• Revisiting the Corporate Transparency Act: The Latest Developments
• An Overview of the Corporate Transparency Act

The attorneys at Barley Snyder continue to follow the Corporate Transparency Act closely and provide updates as new information is released. If you have questions regarding the CTA or the beneficial ownership disclosure requirements, please contact Partner Dan Desmond or any member of the Barley Snyder Corporate Transparency Act Response Team.

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