Corporate Transparency Act: Nationwide Injunction Lifted and Filing Deadlines Reinstated

As we previously reported, on December 3, 2024, in Texas Top Cop Shop, Inc., et al. v. Merrick Garland, Attorney General of the United States, et al., Judge Amos Mazzant of the United States District Court (Eastern District of Texas/Sherman Division) issued a preliminary nationwide injunction barring the enforcement of the Corporate Transparency Act (CTA). 

Today, the Fifth Circuit Court of Appeals stayed the injunction, meaning that the injunction is no longer in effect, and the Financial Crimes Enforcement Network of the U.S. Department of Treasury (FinCEN) may again enforce the CTA.  As of this writing, FinCEN has not extended any filing deadlines.  Therefore, all reporting companies should file immediately any beneficial ownership information reports (BOIRs) that were already due, and reporting companies formed prior to 2024 should file their BOIRs by January 1, 2025.  As an aside, there had been a provision in the initially proposed bill to continue funding the U.S. government that would have extended the January 1, 2025 date by a year, but it was dropped from the funding bill that was ultimately approved and signed into law.