.%20However,%20just%20three%20days%20later,%20on%20December%2026,%202024,%20the%20Fifth%20Circuit%20unexpectedly%20vacated%20that%20order,%20restoring%20the%20injunction.%20As%20a%20result,%20the%20CTA’s%20beneficial%20ownership%20information%20(BOI)%20reporting%20requirements%20remain%20blocked%20once%20again.%20This%20rapid%20reversal%20has%20created%20significant%20confusion%20for%20businesses%20Current%20Status:%20No%20filing%20is%20Required:%20Businesses%20are%20not%20required%20to%20submit%20BOI%20reports%20under%20the%20CTA%20at%20this%20time.%20No%20Changes%20Expected%20Until%20March:%20It%20is%20unlikely%20that%20any%20further%20changes%20will%20occur%20until%20the%20oral%20arguments%20scheduled%20for%20March%202025.%20Voluntary%20Filing:%20While%20we%20do%20not%20expect%20any%20changes%20until%20March%202025,%20businesses%20may%20still%20choose%20to%20voluntarily%20submit%20beneficial%20ownership%20information%20now%20to%20avoid%20any%20potential%20issues%20if%20the%20injunction%20is%20unexpectedly%20lifted.%20Next%20Steps:%20Gutwein%20Law%20understands%20the%20confusion%20this%20situation%20has%20caused,%20and%20we%20want%20to%20reassure%20you%20that%20we%20are%20actively%20monitoring%20developments%20in%20this%20area.%20If%20you%20have%20any%20questions%20or%20need%20further%20clarification%20on%20how%20this%20affects%20your%20business,%20please%20do%20not%20hesitate%20to%20reach%20out%20to%20us.)
On December 23, 2024, the Fifth Circuit Court of Appeals issued an order lifting the nationwide injunction that had previously blocked enforcement of the Corporate Transparency Act (CTA). However, just three days later, on December 26, 2024, the Fifth Circuit unexpectedly vacated that order, restoring the injunction. As a result, the CTA’s beneficial ownership information (BOI) reporting requirements remain blocked once again. This rapid reversal has created significant confusion for businesses
Current Status:
- No filing is Required: Businesses are not required to submit BOI reports under the CTA at this time.
- No Changes Expected Until March: It is unlikely that any further changes will occur until the oral arguments scheduled for March 2025.
- Voluntary Filing: While we do not expect any changes until March 2025, businesses may still choose to voluntarily submit beneficial ownership information now to avoid any potential issues if the injunction is unexpectedly lifted.
Next Steps:
Gutwein Law understands the confusion this situation has caused, and we want to reassure you that we are actively monitoring developments in this area. If you have any questions or need further clarification on how this affects your business, please do not hesitate to reach out to us.
...Read More.%20For%20reporting%20companies%20created%20or%20registered%20in%20the%20U.S.%20on%20or%20after%20September%204,%202024%20that%20had%20a%20filing%20deadline%20between%20December%203,%202024,%20and%20December%2023,%202024:%20The%20new%20deadline%20to%20file%20initial%20reports%20is%20January%2013,%202025.%20For%20reporting%20companies%20created%20or%20registered%20in%20the%20U.S.%20between%20December%203,%202024,%20and%20December%2023,%202024:%20These%20companies%20have%20an%20additional%2021%20days%20from%20their%20original%20filing%20deadline%20to%20submit%20their%20initial%20reports.%20For%20reporting%20companies%20qualifying%20for%20disaster%20relief:%20These%20companies%20may%20have%20extended%20deadlines%20beyond%20January%2013,%202025,%20and%20should%20follow%20whichever%20deadline%20falls%20later.%20For%20reporting%20companies%20created%20or%20registered%20on%20or%20after%20January%201,%202025:%20These%20companies%20must%20file%20their%20initial%20reports%20within%2030%20days%20after%20receiving%20actual%20or%20public%20notice%20of%20their%20creation%20or%20registration.%20Please%20contact%20Gutwein%20Law%20if%20you%20need%20any%20assistance%20in%20complying%20with%20the%20Corporate%20Transparency%20Act.)
%20-%20What%20This%20Means%20for%20Your%20Business&p[summary]=The%20Corporate%20Transparency%20Act%20(CTA)%20requires%20most%20companies%20to%20file%20a%20Beneficial%20Ownership%20Information%20(BOI)%20report%20with%20FinCEN.%20The%20filing%20deadline%20for%20existing%20companies%20is%20January%201,%202025,%20and%20newly%20formed%20companies%20in%202024%20must%20file%20within%2090%20days.%20However,%20on%20December%203,%202024,%20a%20federal%20court%20in%20Texas%20issued%20a%20nationwide%20injunction,%20temporarily%20halting%20the%20enforcement%20of%20the%20CTA.%20The%20court%20ruled%20that%20the%20law%20is%20likely%20unconstitutional.%20What%20Does%20This%20Mean%20for%20Your%20Business?%20No%20Immediate%20Filing%20Requirement:%20You%20are%20not%20required%20to%20submit%20the%20BOI%20report%20(or%20amendments%20to%20previously%20made%20BOI%20reports)%20and%20will%20not%20face%20penalties%20for%20failing%20to%20do%20so%20while%20the%20injunction%20remains%20in%20effect.%20Appeal%20Uncertainty:%20The%20government%20is%20expected%20to%20appeal%20this%20ruling,%20but%20it%20remains%20uncertain%20whether%20the%20appeal%20will%20be%20successful.%20If%20the%20filing%20requirements%20are%20reinstated,%20businesses%20could%20face%20last-minute%20deadlines%20and%20should%20be%20prepared%20to%20comply%20by%20collecting%20the%20necessary%20information.%20Voluntary%20Filing:%20Companies%20can%20still%20choose%20to%20file%20voluntarily%20now,%20which%20may%20help%20avoid%20a%20rush%20if%20the%20injunction%20is%20lifted%20and%20deadlines%20are%20reinstated.%20This%20ruling%20is%20temporary,%20and%20the%20situation%20could%20change%20depending%20on%20the%20outcome%20of%20the%20appeal.%20Please%20contact%20Gutwein%20Law%20with%20any%20questions.)
