Corporate Transparency Act Update: Reporting Obligations Suspended Again

This Client Alert provides latest information in what continues to be the most unexciting developing news story any of us has ever followed. As the saying goes, "Don't shoot the messenger!" Long story short / TLDR (too long didn't read), the U.S. Court of Appeals for the Fifth Circuit ("Fifth Circuit") issued an order on December 26, 2024, which effectively reinstates the preliminary injunction against the enforcement of the Corporate Transparency Act ("CTA"), and once again, it is voluntary for a Reporting Company (as defined by the CTA) to file beneficial ownership information reports ("BOIRs") with the U.S. Treasury's Financial Crimes Enforcement Network ("FinCEN"). As we have mentioned in our prior Client Alerts linked below, this is not a final decision on the constitutionality of the CTA, and businesses should be aware that the reporting deadlines could be reinstated if the most recent order is overturned or a permanent injunction is not awarded on the merits