As a result of a new court decision issued today, December 23, 2024, CTA reporting is back on for the time being. As such, all FMJ clients should comply with the CTA’s BOI reporting requirements, including the all-important January 1, 2025 deadline for preexisting entities.
A few weeks ago, a federal district court issued an order enjoining CTA enforcement nationwide. Click here to learn more. Today, the Fifth Circuit stayed the district court’s injunction while the case is on appeal. The Fifth Circuit also expedited the government’s appeal in the case, but that appeal will not be heard until January at the earliest.
The Bottom Line: while the dispute over the constitutionality of the CTA has not been finally resolved, we now know that the CTA will remain in effect for the time being while that dispute plays out in the courts. In the meantime, FMJ clients should fully comply with the CTA’s BOI reporting requirements.
Please do not hesitate to reach out to Pat Shriver, Brad Hutter, or any of the other members of our Corporate Practice Group with questions about CTA compliance.
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