On December 23, 2024, the Fifth Circuit Court of Appeals reinstated the Corporate Transparency Act's (CTA) requirement for small businesses to report beneficial ownership information (BOI) to the Financial Crimes Enforcement Network (FinCEN). However, just three days later, on December 26, the Fifth Circuit changed course and vacated its own decision in order to preserve the status quo while constitutional arguments are considered on appeal. 

As a result, while the final outcome of the legal proceedings on the BOI files is unknown, for the time being, neither the original filing deadlines, nor the extended filing deadlines (that were the result of the December 23 ruling) are in effect. 

The CTA mandates that small businesses with 20 or fewer full-time employees disclose their beneficial owners to FinCEN, aiming to enhance transparency and combat financial crimes. The recent court rulings underscore the legal challenges surrounding the CTA. Businesses should stay tuned for more information. 

For detailed information on compliance and reporting requirements, businesses should consult FinCEN's official guidelines and filing instructions: https://www.fincen.gov/boi