The nationwide injunction enjoining the Corporate Transparency Act (the “CTA”) was lifted by order of the United States Court of Appeals for the Fifth Circuit on December 23, 2024.  This ruling notably impacts reporting companies subject to the CTA that were formed prior to 2024 and which were facing a January 1, 2025 deadline to submit their initial beneficial ownership information reports (“BOI Reports”) to the Treasury Department.  Absent further direction from either the United States Court of Appeals for the Fifth Circuit or the Treasury Department, reporting companies that were created or registered prior to January 1, 2024 have until January 13, 2025 to file their initial beneficial ownership information reports with FinCEN. (These companies would otherwise have been required to report by January 1, 2025.)

Wiggin and Dana will continue to monitor cases and Treasury announcements related to the CTA and will provide updates as they become available.