IMPORTANT: UPDATE REGARDING THE CORPORATE TRANSPARENCY ACT (CTA) REPORTING REQUIREMENTS AND DEADLINE.

In the spirit of "who's on first, what's on second", once again here is the latest on the on-going CTA litigation that has been taking place this month.

Below is an excerpt from the official FinCen.gov website that speaks specifically to what is currently going on...

On December 23, 2024, a panel of the U.S. Court of Appeals for the Fifth Circuit granted a stay of the district court’s preliminary injunction entered in the case of Texas Top Cop Shop, Inc. v. Garland, pending the outcome of the Department of the Treasury’s ongoing appeal of the district court’s order. FinCEN immediately issued an alert notifying the public of this ruling, and recognizing that reporting companies may have needed additional time to comply with beneficial ownership reporting requirements, FinCEN extended reporting deadlines. On December 26, 2024, however, a different panel of the U.S. Court of Appeals for the Fifth Circuit issued an order vacating the Court’s December 23, 2024 order granting a stay of the preliminary injunction. Accordingly, as of December 26, 2024, the injunction issued by the district court in Texas Top Cop Shop, Inc. v. Garland is in effect and reporting companies are not currently required to file beneficial ownership information with FinCEN.

You can read the entire update from FinCen.gov here...

FinCen-Beneficial Ownership Reporting/Filing Deadline Changes...Again

The bottom line is that this is likely to go on for some time and each person has to make their own decision with the advice of their attorney/accountant as to whether they should just sit and wait this litigation back and forth play out, or just volunteer to file now. 

We will continue to monitor this as it unfolds in the court system...

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Apartment Association of Northeast Wisconsin