THE CORPORATE TRANSPARENCY ACT: FILING DEADLINES SUSPENDED
AGAIN!
The U.S. Court of Appeals for the Fifth Circuit on December 26, 2024, vacated the stay and
reinstated the nationwide preliminary injunction stopping enforcement of CTA and the BOI
reporting requirements. In light of the appellate court’s most recent order, no filings under the
CTA are currently required under the law.
In its order, the appellate court explained that it was taking such action to preserve the
constitutional status quo while the court considers the parties’ substantive arguments on appeal.
Given the appellate court’s order, “reporting companies” are currently not required to file their
BOI reports.
On December 27, 2024, FinCEN announced on its website that given the appellate court’s order
vacating the stay on the preliminary injunction, reporting companies are currently not required to
file beneficial ownership information with FinCEN. Filing of BOI information at this point is
entirely voluntary.
Reporting companies should continue to closely monitor the ongoing litigation regarding
the constitutionality and enforceability of the Corporate Transparency Act.
WHERE CAN YOU FIND MORE INFORMATION?
Beneficial Ownership Information Reporting | FinCEN.gov
HERE you can find FinCEN’s Small Business Resources including:
- Small Entity Compliance Guide,
- Frequently Asked Questions,
- Quick Reference, and
- Short Introductory Video with step-by-step instructions on how to file the BOI report.
COURT ORDER REINSTATING INJUNCTION
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