**CTA Update 2/24/2025**
On February 18, 2025, the U.S. District Court for the Eastern District of Texas stayed its previously issued preliminary injunction on the Corporate Transparency Act (CTA). This means that, at least for now, the CTA and the beneficial ownership information (BOI) reporting requirements are once again back in effect. FinCEN, which administrates the BOI reporting requirements, has announced a 30-day deadline extension, which means that most reporting companies will be required to file a BOI report by March 21, 2025.
FinCEN is also considering further modifications to the reporting deadlines during this 30-day extension period, which may result in modified requirements for lower-risk entities. In any case, reporting companies must nevertheless be prepared to meet the current March 21, 2025, filing deadline. While further modifications to reporting requirements may be forthcoming, for now, companies should be aware of and comply with their reporting obligations.
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**CTA Update 12/27/2024**
FinCEN Extends Corporate Transparency Act Filing Deadline; Fifth Circuit Reinstates Injunction
On December 23, the US Court of Appeals for the Fifth Circuit stayed a lower court’s nationwide injunction on the Corporate Transparency Act. In response, FinCEN extended the filing deadline for existing entities from January 1, 2025 to January 13, 2025. Then on December 26, a panel of the Fifth Circuit vacated the stay and reinstated the injunction blocking the CTA, pending further proceedings. For more information, visit FinCEN’s BOI page at https://fincen.gov/boi.
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**CTA Update 12/4/2024**
Compliance with the Corporate Transparency Act Temporarily Suspended
On December 3, 2024, the U.S. District Court for the Eastern District of Texas issued a preliminary injunction for the enforcement of the Corporate Transparency Act (CTA), finding that the CTA is likely unconstitutional. This means that the Beneficial Ownership Information reporting requirements (existing entities required to file by 1/1/2025) are currently suspended. However, we anticipate additional commentary and appeals to the decision from FinCEN and are actively monitoring for updates. We recommend that entities that are required to report under the CTA continue to gather the needed information in the event the preliminary injunction is lifted.
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The Corporate Transparency Act (CTA), which went into effect on January 1, 2024, requires reporting entities (unless exempt) to file certain information about the entity and its beneficial owners with the Financial Crimes Enforcement Network (FinCEN) by the end of 2024.
You may be required to file a Beneficial Ownership Information Report (BOI Report) under the CTA. See here for general information and resources about the CTA.
