As of December 26, 2024, the United States Court of Appeals for the Fifth Circuit (the “Court”) has reinstated a nationwide preliminary injunction preventing the federal government from enforcing the beneficial ownership reporting requirements imposed by the Corporate Transparency Act (the “CTA”), including the requirement for certain companies (each, a “Reporting Company”) mandated to continuously report certain “beneficial ownership information” (“BOI”) with the Financial Crimes …
FinCEN BOI Reporting Reinstated
FinCEN Beneficial Ownership Reporting Requirements Reinstated: Key Deadlines for Reporting Companies Although a preliminary injunction had temporarily paused requirements under the Corporate Transparency Act (the “CTA”), a December 23, 2024 decision by the United States Court of Appeals for the Fifth Circuit has reinstated the requirement for certain companies (each, a “Reporting Company”) mandated to continuously report certain “beneficial ownership information” (“BOI”) with the Financial Crimes Enforcement …
Nationwide Preliminary Injunction Halts Corporate Transparency Act (“CTA”) Reporting Requirements for Private Funds and Their Advisers
As of December 4, 2024, the U.S. District Court for the Eastern District of Texas (the “Court”) has issued a nationwide preliminary injunction preventing the federal government from enforcing the beneficial ownership reporting requirements imposed by the Corporate Transparency Act (the “CTA”). The CTA, which became effective on January 1, 2024, imposes obligations on millions of entities (each, a “Reporting Company”), including private fund advisers …