Legal Alert
Update: Another Renewal of Enforceability of the Corporate Transparency Act and Extended Filing Deadlines
February 21, 2025
As previously announced, your company may have reporting obligations under the Corporate Transparency Act (“CTA”). With the situation rapidly changing, we wanted to make you aware once again of the current status.
The U.S. District Court for the Eastern District of Texas lifted its nationwide injunction this week against the CTA. Together with the U.S. Supreme Court ruling in McHenry v. Texas Cop Shop, Inc., staying the previous order that blocked the CTA nationwide, the beneficial ownership reporting required under the CTA is again effective.
How Does This Impact My Entity?
If your entity was formed prior to Jan. 1, 2024, is not exempt, and has not already filed, you should generally submit a beneficial ownership report to the Financial Crimes Enforcement Network by March 21, 2025. Newly formed entities formed on or after Jan. 1, 2025, have to file on the later of 30 days after formation or March 21, 2025.
How Do I Know if I’m Exempt?
The CTA applies to all “reporting companies.” A reporting company is any entity that was created by filing a document with the secretary of state or similar office and that does not qualify for an exemption. Generally, exemptions include:
(a) Publicly traded organizations
(b) Large businesses, as defined by the statute
(c) Banks, bank holding companies, and federal or state credit unions
(d) Investment companies
(e) Public utilities
(f) Insurance companies
(g) Tax-exempt organizations
(h) Inactive businesses
Unless an exemption applies, reporting is mandatory.
We Can Help
If you have questions about how to prepare your company for the CTA, please write to us at CTACompliance@maslon.com.