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On December 23, 2024, the 5th Circuit Court of Appeals lifted a nationwide injunction which halted the enforcement of the Corporate Transparency Act’s reporting requirements. Immediately following, FinCEN released updated deadlines which primarily moved the January 1, 2025, filing deadline to January 13, 2025. However, it was ordered that the appeal be expedited to the next available oral arguments panel for the 5th Circuit Court of Appeals. And on December 26, 2024, that new panel issued another order reinstating the nationwide injunction “to preserve the constitutional status quo while the merits panel considers the parties’ weighty substantive arguments.” Therefore, the nationwide injunction is back in place although FinCEN has not yet reissued new deadlines or guidance.
Provident Law continues to monitor the appeal. If you have any questions or desire to voluntarily comply with the CTA reporting requirements given the uncertain landscape, please feel free to contact our Firm.
Kyle McCutcheon is an attorney at Provident Law. His practice areas include business, real estate, and estate planning as well as advising church and nonprofit tax-exempt organizations. McCutcheon is licensed to practice law in Arizona and Missouri, and he can be reached at kyle.mccutcheon@ProvidentLawyers.com or at 480-388-3343.
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