Dec 27, 2024
In another surprising turn of events, the Fifth Circuit Court has now vacated the stay that was put into effect on December 23, 2024 that reinstated enforcement of the Corporate Transparency Act (CTA). On December 26, 2024, the Court reinstated the preliminary suspension of reporting requirements under the CTA. The Court issued this decision in anticipation of an expedited ruling on the merits of the nationwide injunction that was put into place on December 3, 2024. As a result, all filing deadlines under the CTA are once again suspended until further notice from the Court, including the obligation to file by January 13, 2025 an initial beneficial ownership information (BOI) report for all “reporting companies” formed or registered prior to January 1, 2024. The Financial Crimes Enforcement Network (FinCEN) posted the following alert on its homepage https://www.fincen.gov/boi: “In light of a recent federal court order, reporting companies are not currently required to file beneficial ownership information with FinCEN and are not subject to liability if they fail to do so while the order remains in force. However, reporting companies may continue to voluntarily submit beneficial ownership information reports.”
Reporting companies should continue to monitor closely the fast-moving developments with respect to enforcement of the CTA.
Jackson Tidus attorneys are ready to assist you in complying with the CTA and its filing requirements. Accordingly, if you have questions about the CTA or need help with filings, changes to your governance documents or other guidance or assistance, please do not hesitate to contact Jackson Tidus.
Elizabeth T. Hall, Esq.
phone: 949-851-7466
email: ehall@jacksontidus.law
Mona Goodarzi
phone: 949-851-7627
email: mgoodarzi@jacksontidus.law
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