Articles and Updates
Whiplash: The Corporate Transparency Act Is Reinstated—and then Paused Again
On December 23, 2024, the U.S. Court of Appeals for the Fifth Circuit reinstated the Corporate Transparency Act (CTA) beneficial ownership information (BOI) reporting requirements. The reinstatement came just 20 days following a nationwide preliminary injunction issued by a lower court which had temporarily blocked enforcement of the CTA and its reporting requirements (see our prior article here). The same day, FinCEN issued an alert extending the applicable reporting deadlines for many companies, though not significantly.
Three days later on December 26, 2024, the Fifth Circuit reversed course and paused the BOI reporting requirements—again. The government is appealing the lower court’s decision and could seek further relief from the Fifth Circuit or the U.S. Supreme Court, which could result in reinstatement of the CTA’s BOI reporting requirements.