The never-ending saga of the Corporate Transparency Act (CTA) continues. On December 23,
2024, the Fifth Circuit granted the Department of Justice’s request to stay the nationwide
injunction that was put in place on December 3, 2024 by a federal judge in the Eastern District
of Texas. The Department of the Treasury responded to the stay by extending the beneficial
ownership information (BOI) filing deadline to January 13, 2025.
On December 26, 2024, the Fifth Circuit vacated its own order to stay the injunction effectively
temporarily ending the requirement to make a BOI filing. It should be noted that the Fifth
Circuit has not decided the merits of the case. The First Circuit’s stay only applies to the
deadline for the filing requirement. As with any litigation, the outcome is uncertain.
Due to the potential for significant penalties if a timely BOI filing is not made, Wagner, Shields
& Moini LLP continues to recommend that clients make a voluntary BOI filing to ensure timely
compliance in the event that the CTA is upheld.
