On December 26, 2024, the Fifth Circuit reversed the US Court of Appeals decision to enforce the Corporate Transparency Act (the “CTA”). This means that the reporting requirements under the CTA are once again halted.
As the reversal stands, reporting companies are not currently required to file beneficial ownership information report (a “BOI report”) reports in compliance with the CTA. Given the uncertainty regarding the fate of the CTA, for the time being, we recommend continuing the process of determining which entities meet the definition of a reporting company, identifying beneficial owners and gathering the required information for BOI reports to be prepared to meet any applicable filing deadlines, including January 13, 2025.
Please contact your Sheehan Service Partner if you have any questions.
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