The Beneficial Ownership Information (BOI) reporting obligations under the Corporate Transparency Act and its implementing regulations (together, the “CTA”) are once again paused.
On December 26, 2024, the U.S. Circuit Court of Appeals for the 5th Circuit issued an order that reinstates the preliminary injunction from December 3, 2024. The federal court issued the order in Texas Top Cop Shop v. Garland, 24-40792, reversing the decision to lift the injunction preventing enforcement of the Corporate Transparency Act (CTA) and the related Reporting Rule requiring companies to file Beneficial Ownership Information (BOI) reports with the Financial Crimes Enforcement Network (FinCEN).
What does it mean?
Until further notice, the CTA cannot be enforced and companies will not be penalized for failing to submit BOI reports while this litigation challenging the constitutionality of the CTA is pending. The case has been scheduled for oral argument on March 25, 2025.
As a result, reporting companies need not comply with the CTA’s extended January 13, 2025, deadline.
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About the Corporate Transparency Act
News Coverage:
Forbes
National Law Review
