December 26, 2024 UPDATE: On December 26rd, a merits panel on the Fifth Circuit Court of Appeals stayed the ruling that vacated the nationwide injunction against beneficial ownership information (BOI) reporting requirement.  As such, the injunction against BOI reporting requirements is back in effect, meaning that BOI reporting is voluntary until further developments occur.

The CTA has been the subject of several high profile court cases, including the case addressed by the Fifth Circuit Court of Appeals in this injunction reversal.  Notably, there still exists another, more limited injunction from an federal district court out of Alabama in the Eleventh Circuit.  That court's ruling enjoins enforcement against BOI reporting requirements from members of the Small Business Administration (SBA) who were members at the time of the ruling.  Nat'l Small Bus. United v. Yellen, 721 F. Supp. 3d 1260 (N.D. Ala. March 1, 2024).

Groups and individuals called upon FinCEN to extend the deadline in the wake of the injunction being reversed as close as it was when compared to the original January 1, 2025 deadline.  FinCEN granted that request, and now the deadline for most entities to comply with FinCEN's BOI reporting requirements will be January 13, 2025.

Please stay tuned for the latest updates on the ongoing litigation involving the CTA by subscribing to the Farm Law & Tax website.