The U.S. Supreme Court issued an order reviving the Corporate Transparency Act (CTA) and its Beneficial Ownership Information (BOI) reporting requirements. Reporting entities established before 2024 had been required to file an initial BOI report with the Financial Crimes Enforcement Network (FinCEN) by Jan. 13. However, the U.S. Court of Appeals for the 5th Circuit issued a Dec. 26 stay pausing enforcement of reporting requirements while it considered the case.
The Supreme Court’s two-page order did not provide the reasons for reversing the 5th Circuit’s stay on CTA enforcement. Still, the high court said the act can be enforced until the 5th Circuit has decided its constitutionality. The order also said the CTA would remain in force while the Supreme Court was considering whether to hear any appeals of the 5th Circuit’s ruling on the CTA.
FinCEN has yet to respond to the Supreme Court’s order, and it is unclear when businesses must file their initial BOI report with the agency. We will continue to monitor developments regarding BOI reporting and alert you to any changes or updates as they occur.
