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CTA Filing Obligations Reinstated; Nationwide Injunction Lifted

By John Crowe, Erica Howard-Potter, Robert C. Lamonica, and Ronald Shechtman
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The Corporate Transparency Act (“CTA”) is once again in full force, including its statutory filing deadlines.  The 5th U.S. Circuit Court of Appeals placed a hold on the nationwide injunction that halted the enforcement of the CTA, which injunction was imposed by a Texas federal judge on December 3, 2024.

Under the CTA, entities that existed before 2024 must complete the reporting process before January 1, 2025.  However, in light of the previous injunction, those reporting companies have until January 13, 2025, to file their initial beneficial ownership information reports with FinCEN.

Please contact your Pryor Cashman attorney with any questions you may have.