On December 26, 2024, the US Court of Appeals for the Fifth Circuit paused the Corporate Transparency Act (CTA)’s beneficial ownership information (BOI) reporting requirements in Texas Top Cop Shop, Inc. et al. v. Garland et al. This follows a preliminary injunction issued on December 3, 2024, which initially halted the BOI requirements, and a subsequent stay issued on December 23, 2024, that temporarily reinstated them. The stay was vacated on December 26, effectively pausing the requirements once again.
As a result, companies are not currently required to file BOI reports by the January 13, 2025, deadline. However, given the ongoing uncertainty in this litigation, companies should carefully evaluate whether to prepare and potentially file reports proactively.
We are closely monitoring the situation and will provide updates as more information becomes available.
This alert is for informational purposes only and does not constitute legal advice.