The date of this post, January 13, 2025, was the amended deadline for reporting under the Corporate Transparency Act’s Beneficial Ownership Information requirement — but was blocked in late December 2024 by the Fifth Circuit Court of Appeals. At this time, the issue is still “on hold,” pending response by the Supreme Court of the United States.
Recent Activity Since the Reinstated Injunction
This recent post to the SCOTUS Blog on January 1, 2025 provides an update including the government’s response seeking enforcement of the anti-money laundering law.
This webpage lists January 2025 amicus briefs and responses.
Previous Activity in December 2024
The following was shared to our contacts via the December 2024 Cowles Thompson Business & Legal Update newsletter:
Fifth Circuit Reverses Course — Blocks Enforcement of Beneficial Ownership Reporting
Via NFIB.com
Dec. 3, 2024:
Our prior dissemination of this newsletter noted that a District Court in Texas had placed a preliminary nationwide injunction on the new Beneficial Ownership Information (BOI) reporting requirements imposed by the Corporate Transparency Act (CTA). In Texas Top Cop Shop, Inc. v. Garland, No. 4:24-CV-478 (E.D. Texas) the judge ruled that “[a] nationwide injunction is appropriate in this case,” which earlier this month meant that “reporting companies need not comply with the CTA’s Jan. 1, 2025, BOI reporting deadline pending further order of the Court.”
Dec. 23, 2024:
The U.S. Court of Appeals for the Fifth Circuit blocked the injunction – allowing the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) to enforce the CTA and its BOI reporting requirements. At that time, the original deadline of 12/31/24 was updated to a deadline of 1/13/25.
Dec. 27, 2024:
The Fifth Circuit’s latest decision reinstates the nationwide injunction — blocking the BOI reporting requirements for small businesses; the court will more fully consider the government’s appeal in the meantime.
Stay tuned, as there is uncertainty about how the incoming Trump Administration and/or Congress will handle enforcement.
See also:
- The Guide to the Corporate Transparency Act and Beneficial Ownership Information filing for small businesses in 2024 – via Rockerbox.
- Our article from April 2024: Groundbreaking US Corporate Transparency Act and What Business Owners Should Know.
