CTA Stayed Once Again – No BOI Reports Required At This Time

On December 26, 2024, the U.S. Court of Appeals for the Fifth Circuit reinstated the nationwide preliminary injunction enjoining enforcement of the Corporate Transparency Act (the “CTA”) and the rules and regulations promulgated thereunder, including the requirement of non-exempt entities to file Beneficial Ownership Information reports (“BOI Reports”). As such, no BOI Reports are required to be filed with the U.S. Treasury Department’s Financial Crime Enforcement Network bureau (“FinCEN”). Earlier last week, a separate Fifth Circuit panel had stayed a lower court ruling that had issued the nationwide preliminary injunction and FinCEN, following the Fifth Circuit’s initial ruling staying the enforcement of the CTA and filing requirement rules, had extending the deadline for filing BOI Reports.