As previously discussed (here), in December of 2024 a Federal District Court and the 5th Circuit Court of Appeals issued a series of decisions ultimately resulting in an order enjoining enforcement of the Corporate Transparency Act.
On January 23, 2025, the Supreme Court stayed this injunction, pending further consideration by the 5th Circuit Court of Appeals. However, there is another nationwide order issued by a different Federal District Court that remains in place, and the government states “reporting companies are not currently required to file beneficial ownership information with FinCEN despite the Supreme Court’s action”.
While the requirement to disclose beneficial ownership information continues to be on hold, FinCEN still allows for voluntary compliance with the rules. Some businesses may choose to file disclosures to avoid issues down the road if reporting once again is made mandatory.
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