This week brought further developments related to the legal challenge to the Corporate Transparency Act ("CTA") and its Beneficial Ownership Information Report ("BOIR") filing obligations.
We understand how confusing and frustrating this back-and-forth can be for business owners and their advisors, and we're committed to keeping you informed.
Updates as of 12/26/2024:
On December 23, 2024, the U.S. Court of Appeals for the Fifth Circuit issued a decision that reversed a Texas district court’s preliminary injunction in the case of Texas Top Cop Shop, Inc., et al. v. Garland, et al.
This decision temporarily lifted the nationwide hold on the enforcement of the CTA, reinstating the BOIR filing requirements.
In response, the Financial Crimes Enforcement Network ("FinCEN") announced revised filing deadlines:
Reporting companies formed before 2024 or those formed after September 4, 2024, with filing deadlines originally set between December 3, 2024, and December 23, 2024, must now submit their BOIR filings by January 13, 2025.
However, on December 26, 2024, the full Fifth Circuit Court intervened, reversing the earlier panel’s decision.
The stay on CTA enforcement was reinstated nationwide, halting BOIR obligations while the case undergoes expedited appellate review.
As of now, FinCEN’s revised deadlines are no longer enforceable.
What This Means for You
The ongoing litigation has created uncertainty surrounding the enforcement of the CTA and the associated filing obligations. For now, reporting companies are not required to file BOIRs, but the situation remains fluid + subject to change.
At PB Law, we’re closely monitoring these developments to ensure our clients + friends informed of any updates or changes to CTA compliance requirements. As the legal landscape evolves, we are committed to providing the guidance you need to stay compliant and minimize risks. Stay tuned for further updates as we continue to track this important issue!
Need Guidance?
If you’re unsure how this development impacts your business or need help preparing for potential reporting obligations, contact us. Our team is here to help navigate this evolving legal landscape and ensure you’re prepared for any changes.
Current PB Law Clients can schedule a BOI / CTA Q+A Meeting here:
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Read More about the CTA:
- Tiffany Ballenger Floyd, Esq. | Managing Partner, Phillips Ballenger Estate Attorneys | Licensed in NV + CA