Corporate Transparency Act Whiplash

Yesterday, December 23, 2024, the U.S. Fifth Circuit Court of Appeals issued a stay of the nationwide preliminary injunction on enforcement of the Corporate Transparency Act (CTA), which injunction had been ordered by the U.S. District Court for the Eastern District of Texas on December 3, 2024.

The result of this ruling from the Fifth Circuit is that, subject to any guidance from FinCEN, (1) the original CTA reporting deadlines were put back in effect, with the most pressing being the January 1, 2025, deadline for entities that were formed prior to January 1, 2024, and (2) FinCEN may enforce the CTA reporting requirements and impose the stated fines for those entities which fail to meet the deadlines.