The legal battle over the Corporate Transparency Act (CTA) continues. As of today, December 27^th, 2024, the preliminary injunction has been reinstated, temporarily halting enforcement of the CTA, including the requirement to file Beneficial Ownership Information (BOI) reports. To avoid any confusion, a timeline of relevant decisions is below:

• Tuesday, December 3^rd, 2024, the District Court for the Eastern District of Texas ordered a nationwide injunction of the CTA and halted enforcement of the act, including the requirement to file BOI reports by January 1, 2025.

• Monday, December 23^rd, the Fifth Circuit Court of Appeals stayed the injunction, reinstating the reporting requirement. FinCEN then immediately extended the reporting deadline to January 13, 2025.

• Thursday, December 26^th, the Fifth Circuit reversed its order and vacated the stay of the injunction, once again halting the CTA and the BOI reporting requirements.

As of today, the CTA’s reporting requirements, including the new January 13, 2025, filing deadline, have been put on hold. The Fifth Circuit is expected to issue a briefing schedule in the coming days, which will give insight as to when we can anticipate further announcements or changes to the reporting requirements.

Reports may be filed voluntarily at https://boiefiling.fincen.gov/boir/html. As part of our commitment to our clients, we will continue to monitor the case and provide updates as they become available.

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