CTA Filing Obligations on Hold – Again!

The month of December has been a roller coaster for most business owners with respect to their Beneficial Ownership Interest (BOI) filing obligations under the Corporate Transparency Act (CTA).  In the latest news, on December 26, 2024, the Fifth Circuit Court of Appeals vacated its stay and reinstated the nationwide injunction prohibiting the CTA from being enforced.  The injunction, first issued on December 3, 2024 by the U.S. District Court for the Eastern District of Texas in Texas Top Cop Shop, was briefly stayed by the Fifth Circuit.  The stay caused the CTA to become enforceable again, and resulted in FinCEN releasing extended deadlines for BOI filings.

At this time, there are no BOI filing obligations for any companies.  This includes both the initial reports for companies that had not yet filed, and the update reports for companies that had a change in BOI information since their initial report was filed.

This article was written by Rachel L. Partain, a partner in the firm’s Corporate and Mergers & Acquisitions practice group. If you have questions regarding the CTA, please reach out to Ms. Partain or another Corporate partner at 516-248-1700.