On December 3, 2024, the U.S. District Court for the Eastern District of Texas granted a nationwide preliminary injunction enjoining enforcement of the Corporate Transparency Act (CTA). The decision temporarily paused BOI reporting requirements under the CTA. On December 23, 2024, the U.S. Court of Appeals for the Fifth Circuit issued a stay of the injunction. The Court of Appeals stay reinstated the BOI reporting obligations while the Department of Treasury’s appeal of the December 3rd decision proceeds.
As a result, reporting companies are once again required to file BOI reports with the Financial Crimes Enforcement Network (FinCEN). Recognizing the impact of the recent preliminary injunction and the time required to achieve compliance, the Department of the Treasury has extended certain reporting deadlines based upon when the reporting company was created or registered, or if the company is eligible for disaster relief in connection with victims of Hurricanes Beryl, Debby, Francine, Helene and Milton.