Client Alert: Injunction on Corporate Transparency Act Reinstated

Yesterday, December 26, 2024, the Fifth Circuit Court of Appeals reinstated the nationwide injunction imposed on enforcement of the Corporate Transparency Act’s (“CTA”) beneficial ownership reporting requirements. What this means to reporting companies is that the current deadline of January 13, 2024, can no longer be enforced by FinCEN during the period in which the parties to the pending litigation continue to brief the matter for the Fifth Circuit. During this period, reporting companies are encouraged to proceed with gathering the needed information to complete the beneficial ownership reporting requirement of the CTA. Once collected, reporting companies can choose to either voluntarily report and complete the filing or wait to hear the decision of the Fifth Circuit. Either way it is important to be prepared and ready to file as we have now seen that any deadline extensions which may occur will be brief.

Additional information about the CTA and specific instructions regarding the online reporting process, including step-by-step instructions, can be found at https://fincen.gov/boi and https://boiefiling.fincen.gov/help.

Commonwealth Trust Company is pleased to provide this article as a guide. Commonwealth Trust Company is not engaged in the practice of law and is not providing legal advice by the provision of these materials. Commonwealth Trust Company recommends that clients seek the opinion of their attorney regarding the specific legal and tax issues addressed in this article.