Company Law Update - Rules for Reporting Beneficial Ownership of Entities Reinstated and Deadlines Extended
On December 23, 2024, the Fifth Circuit Court of Appeals reinstated the application of the beneficial reporting requirements under the Federal Corporate Transparency Act. For our earlier summary of the federal beneficial ownership reporting requirements, see here.
FinCEN has issued updated reporting deadlines:
- Reporting companies created or registered before January 1, 2024: Deadline extended to January 13, 2025 (previously January 1, 2025).
- Reporting companies created or registered between September 4, 2024, and December 23, 2024: Deadline extended to January 13, 2025.
- Reporting companies created or registered between December 3, 2024, and December 23, 2024: Deadline extended by 21 days from their original deadline.
- Reporting companies created or registered on or after January 1, 2025: Must file within 30 days of their creation or registration.
- Disaster Relief Extensions: Companies qualifying for disaster relief may have deadlines that extend beyond January 13, 2025, and should follow the later date.
Under New York State law, the reporting requirements for limited liability companies, summarized in our earlier article (see here), have been postponed until January 1, 2026 and compliance must be completed by January 1, 2027:
- Reporting LLCs created before January 1, 2026: Deadline extended to January 1, 2027.
- Reporting LLCs created on or after January 1, 2026: Must file at the time the Articles of Organization are filed.
If you are not exempt from the reporting requirements and have not yet arranged for the filing of the beneficial ownership information report for a reporting company, we are here to assist you in filing the applicable beneficial ownership information report for all required reporting companies or, if unsure whether you must file, to assist you in determining whether you are required to file.
Please contact: Simon Gerson (212) 790-9206 or Robert J. Giordanella (212) 790-9234 for assistance. ATTORNEY ADVERTISING
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Simon has more than 30 years of experience counseling and attending to the varied commercial and corporate needs of established privately-held businesses and their principals.
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Bob concentrates on succession planning and estate and trust administration.
He also handles significant commercial transactions, including the purchase and sale of publishing and other media related companies and businesses involved in the sale, distribution or manufacture of various consumer products.