On December 23, 2024, a panel of judges in the Fifth U.S. Circuit Court of Appeals stayed the nationwide preliminary injunction concerning the Corporate Transparency Act (CTA). Just three days later, on December 26th, another panel of judges reinstated the...
On December 23, 2024, a panel of judges in the Fifth U.S. Circuit Court of Appeals stayed the nationwide preliminary injunction concerning the Corporate Transparency Act (CTA). Just three days later, on December 26th, another panel of judges reinstated the injunction, creating renewed uncertainty for reporting companies. On December 31st, the U.S. Department of Justice filed an application with the U.S. Supreme Court to halt the injunction, aiming to restore the enforcement of the CTA during the appeal process.
The Financial Crimes Enforcement Network (FinCEN), tasked with administering the CTA, has acknowledged that reporting companies are not required to file beneficial ownership information reports (BOIRs) while the injunction remains in effect. However, FinCEN continues to accept voluntary filings for those choosing to proceed despite the pause.
Oral arguments regarding the injunction have been scheduled for March 25, 2025. Meanwhile, the government may appeal to the Supreme Court, which could significantly alter the timeline or outcomes. The DOJ’s recent application to the Supreme Court could expedite resolution and potentially reinstate the CTA’s requirements sooner than anticipated. Until further legal clarity emerges, AAFCPAs advises clients to navigate this shifting regulatory landscape carefully.
Organizations that have not yet filed a BOIR are now faced with several options.
The CTA remains a critical regulatory consideration for many businesses. Staying informed and prepared will help mitigate risks as developments unfold. AAFCPAs is monitoring these developments and will provide updates and resources as appropriate to assist clients in navigating these requirements.
If you have questions, please contact Erica Nadeau, CPA, MST, Tax Partner at 774.512.4111 or enadeau@aafcpa.com—or your AAFCPAs Partner.
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