The firm has previously notified our clients and network about an obligation to make certain filings under the Corporate Transparency Act (CTA) that became effective at the beginning of 2024.
It provided deadlines to file Beneficial Ownership Information (BOI) for many companies by December 31 of this year, and in some cases required earlier deadlines.
As you may know, a number of lawsuits were filed in various federal courts around the country aimed at declaring the CTA unconstitutional or otherwise limiting its enforcement. In early December, one district court ordered a nationwide injunction against enforcement of the CTA. This order went to an appellate court that, this past Monday, overturned the injunction, and then on Wednesday reversed itself and reinstated the nationwide injunction.
As a result of all these competing decisions, the current status, as of the end of 2024, is that the government may not currently enforce the CTA rules. Therefore, as long as the current injunction remains in place, there is no obligation for any of our clients to file BOI reports, although such reports may still be filed voluntarily.
There will clearly be additional decisions from various courts, and whether the CTA is ultimately enforceable will probably be decided by the U.S. Supreme Court in the new year. We will provide updates as they occur.
If you have any questions, please don’t hesitate to contact [email protected].
