CTA Injunction Reinstated – Reporting Requirements on Hold…AGAIN

On December 26, 2024, the U.S. Court of Appeals for the Fifth Circuit reinstated the district court’s preliminary injunction in Texas Top Cop Shop, Inc., et al.  v. Garland, et al. As a result, the requirement to file Beneficial Ownership Information (BOI) under the Corporate Transparency Act (CTA) is now on hold until the merits panel can fully consider the government’s appeal. For information on the initial suspension of the CTA, see our December 4, 2024 alert HERE.

What Does This Mean for Your Business?

• Filing Deadlines Suspended: Though the obligation to file BOI under the CTA has been suspended, FinCEN continues to accept voluntary submissions.
• Our Recommendation: Considering the rapidly evolving landscape, businesses should discuss voluntary reporting with their legal counsel while remaining prepared to file if the injunction is lifted.

If you have questions or concerns regarding these changes, contact Jason Lederman at jlederman@steinadlerlaw.com or 917.639.5121.