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news & events / 01.24.25 /Kenneth R. Jacobs

CTA Reporting Requirements Restored! The Supreme Court grants Government’s request to vacate the stay of enforcement of the CTA

In our last episode, the Fifth Circuit Appeals Court had reinstated the nationwide injunction against enforcement of the CTA pending the court’s consideration of the merits of the Government’s appeal of the injunction initially granted by the District Court. The Government filed an emergency motion with the Supreme Court to lift the stay.

On January 23, 2025, the Supreme Court granted the Government’s motion, lifting the injunction until the Fifth Circuit has ruled on the Government’s appeal and the Supreme Court has either granted or denied a “writ of certiorari” (motion for a further appeal) by the losing party. The Court’s decision appears HERE. The appeal process could take several months.

This means that the Beneficial Ownership Information reporting requirements of the Corporate Transparency Act are reinstated for the foreseeable future. We expect FinCEN to set a new, short filing deadline very soon. We will advise you when it is announced.

As detailed in our E-blasts from [August 2024] [October 2024], companies that wish to file independently can do so by going to https://boiefiling.fincen.gov/. Individuals who wish to obtain a personal identification number if they need to make multiple filings can do so by going to FinCEN’s step-by-step instructions for filing HERE. Your managing agent and other third-party companies may also offer their services for filing for a fee. Companies that wish to use our firm’s services to file may contact Vanessa Martinez [vmartinez@sbjlaw.com] to compile and submit their filings.

Thank you for staying connected with us. As we wrap up the week, we hope you have a wonderful weekend ahead. Stay warm, and please don’t hesitate to reach out if you have any questions or need further assistance.