U.S. Court of Appeals Pauses Enforcement of the CTA
The U.S. Court of Appeals for the Fifth Circuit paused the enforcement of the CTA on December 27, 2024. This is a reversal of an earlier decision on December 23, 2024, that reinstated the CTA and moved beneficial ownership information (BOI) reporting requirement deadlines to January 13, 2025. The U.S. Department of Justice has asked the U.S. Supreme Court to halt the nationwide injunction against the CTA, which would allow enforcement of the law during an appeal.
While reporting is not currently required, please be prepared to file BOI reports immediately if enforcement is resumed. The current reporting deadline is January 13, 2025, and while FinCEN may again adjust the deadlines, there is no guarantee that they will do so.
Should enforcement be reinstated, reporting companies that were created or registered in the United States after January 1, 2024, should also refer to FinCEN’s website to review the Alert summarizing those filing deadlines.
For more information, read our blog post, The Corporate Transparency Act (CTA): What You Need to Know, to learn about key reporting requirements, timelines, and tips for filing. For additional assistance, please contact us or reach out to your Perkins advisor.