Corporate Transparency Act Enforcement Temporarily Halted Once Again

On December 26, 2024, the U.S. Court of Appeals for the Fifth Circuit reversed its own prior ruling, and reinstated an injunction previously issued by a lower Federal Court in Texas. This injunction blocks the enforcement of the Corporate Transparency Act (CTA) and its reporting rules, which require the filing of Beneficial Owner Information by January 1, 2025.

As it stands now, reporting companies are not required to submit beneficial ownership information under the CTA by the December 31, 2024, deadline. But, given the ongoing uncertainty surrounding the CTA, and the almost daily rulings on this matter, we recommend that clients stay informed about further developments and remain prepared to file the required reports should the injunction be lifted. While not legally necessary, clients may also consider submitting a voluntary filing as a precautionary measure. Voluntary BOI filings are being accepted at this time.

Please do not hesitate to contact us with any questions regarding this update.