CTA Whiplash – As of December 26, 2024 Voluntary Submissions Only
December 3, 2024 – The U.S. District Court for the Eastern District of Texas granted a preliminary injunction blocking the U.S. Department of Treasury from enforcing the Corporate Transparency Act (CTA) – including the January 1, 2025 beneficial ownership information (BOI) report filing requirement for companies formed prior to January 1, 2024.
December 23, 2024 – The Department of Justice appealed this decision and on December 23, 2024, the Federal Court of Appeals for the Fifth Circuit issued a ruling staying the preliminary injunction issued on December 3, 2024. FinCEN issued an alert notifying the public of this ruling, and recognizing that reporting companies may need additional time to comply with beneficial ownership reporting requirements, extended reporting deadlines.
December 26, 2024 – A different panel of the U.S. Court of Appeals for the Fifth Circuit issued an order vacating the Court’s December 23, 2024 order granting a stay of the preliminary injunction.
What does this mean?
As of December 26, 2024, the injunction issued by the district court in Texas Top Cop Shop, Inc. v. Garland is in effect and no reporting is required with FinCEN.
Questions? Please contact a member of PK Law’s Corporate and Real Estate Group or contact information@pklaw.com and include CTA Report in the email subject line.
SOURCE: https://www.fincen.gov/boi
Please Note: The filing of the Beneficial Ownership Information (“BOI”) Report is the responsibility of the entity and its beneficial owners. PK Law Attorneys will not take any action or file any BOI reports, whether or not currently or previously engaged as an Attorney for the entity or any of the entity’s beneficial owners, unless expressly engaged to do so.
