After reinstating the Corporate Transparency Act’s (“CTA”) filing deadline on December 23, 2024, just three days later, on December 26th, the United States Court of Appeals for the Fifth Circuit reversed course and effectively paused the deadline yet again during the pendency of that appeal. The Court stated that it overturned the reinstated reporting requirements “in order to preserve the constitutional status quo” while the merits panel reviews the Government’s appeal of the initial injunction from a Federal Court in Texas on December 3, 2024.
What Does This Mean For Businesses?
This new ruling once again temporarily suspends the Beneficial Ownership Information (BOI) reporting requirements that would be required for covered companies under the CTA and lifts the previously extended reporting deadlines from the Financial Crimes Enforcement Network (FinCEN). This ruling is in effect while the Court considers the Government’s appeal following the December 3, 2024, preliminary injunction that initially paused the BOI reporting requirements, with the briefing schedule still to be released.
The Corporate Transparency Act remains a highly-contested matter as it works its way through the courts. Davis, Burch & Abrams will closely monitor legal events related to CTA and will issue additional Client Alerts as developments unfold.
If you have any questions, or if you wish to engage Davis, Burch & Abrams to assist you with CTA compliance, please call us at 757-410-2293 or email rochelle.kizzee@davisba.com.