Corporate Transparency Act Redux

After repeated starts and stops, beneficial ownership reporting obligations under the Corporate Transparency Act (CTA) are back in effect as of February 18, 2025, due to a stay of the nationwide injunction that suspended reporting obligations under the CTA.

Every “reporting company” (almost every legal entity formed or operating in the US) which has not yet filed the required beneficial ownership information report needs to do so before the updated reporting deadlines:

• 1. Generally, March 21, 2025, for reporting companies formed before February 18, 2025.
• 2. Within 30 days after the date of formation, for reporting companies formed on or after February 18, 2025.
• 3. The later of (a) March 21, 2025 or (b) 30 days after any change or discovery of an error in a BOIR, for reporting companies which have already filed their initial BOIR.
• 4. Previously granted extended deadlines, for reporting companies granted extensions due to disaster relief.

Litigation, regulatory and legislative efforts to eliminate the CTA requirements are ongoing, and DDRS continues to monitor developments.  Clients with questions about CTA matters should reach out to their primary contact within the firm.