December 23, 2024 Update on Fifth Circuit Temporary Stay
On December 23, 2024, the Fifth Circuit Court of Appeals GRANTED the Government’s emergency motion for a temporary stay of the nationwide injunction that blocked enforcement of the Corporate Transparency Act (CTA) through Texas Top Cop Shop, Inc. et al. v. Garland et al., No. 4:24-cv-478 (E.D. Tex.; Dec. 3, 2024). This means that all “reporting companies” who have not already submitted their beneficial ownership information (“BOI”) reports with Financial Crimes Enforcement Network (FinCEN) should timely submit their BOI reports by the reporting deadlines to comply with the CTA.
The original reporting deadline for “reporting companies” formed prior to January 1, 2024 was January 1, 2025. FinCEN has now extended the initial filing deadline for these “reporting companies” from January 1, 2025 to January 13, 2025 (for further details please refer to FinCEN’s website).
We will continue to monitor the legal proceedings, and provide further updates to the CTA as they develop.
