On December 26, 2024, new developments emerged regarding the Corporate Transparency Act (CTA).
After originally lifting the injunction staying enforcement of the CTA and the Financial Crimes Enforcement Network (FinCEN) setting a new deadline of January 13, 2025, the Fifth Circuit Court of Appeals reversed course and reinstated the injunction pending another hearing. This unexpected reversal means that reporting companies will not be required to file beneficial ownership information (BOI) while the injunction is in effect.
If you decide to wait to file a BOI report, it may be beneficial to continue to assemble information related to the BOI report. Reporting companies should be prepared to file the report on a short timeline if the injunction is lifted again.
The Gordon Rees Scully Mansukhani Business Transactions team will continue to closely monitor the situation. Due to its evolving nature, we will post further updates directly on our website rather than circulating individual alerts.
For your convenience, we have linked our previous client alert, which outlines the CTA filing requirements. Should you need assistance with the filing process or have any questions about the CTA, please see the Small Entity Compliance Guide or contact an attorney in the Business Transactions group, including the following GRSM team members: Craig Heryford at cheryford@grsm.com, Ronit Stone at rstone@grsm.com, Carol Schaner at cschaner@grsm.com, Elizabeth Hitt at ehitt@grsm.com, and Dan Graziano at dgraziano@grsm.com.