Recent federal court decisions leave CTA deadlines in flux, prompting businesses to closely review compliance obligations.
NEW JERSEY – In a rapidly shifting legal landscape, the Corporate Transparency Act (CTA)—which obliges most domestic and foreign companies doing business in the United States to file Beneficial Ownership Information (BOI) reports—has seen its enforcement toggled multiple times in recent days.
On December 26, 2024, the U.S. Court of Appeals for the Fifth Circuit “vacated a previous stay on the nationwide injunction against enforcing the Corporate Transparency Act (CTA). This effectively halts all CTA reporting requirements temporarily.” Despite this development, the guidance remains that “Entities should still evaluate their reporting obligations and consider voluntary reporting via FinCEN’s system.”
Background and What the CTA Requires
Under the CTA, effective January 1, 2024, most corporations, limited liability companies, and similar entities “must file Beneficial Ownership Information (BOI) reports with FinCEN.”