Fifth Circuit Again Pauses Corporate Transparency Act’s Beneficial Ownership Report Rule
The Fifth Circuit Court of Appeals has reinstated the nationwide injunction blocking the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) from enforcing the Corporate Transparency Act’s beneficial ownership reporting rule. As a result, reporting companies are again under no obligation to file their beneficial ownership reports. On December 3, a Texas federal district court issued a nationwide injunction blocking enforcement of the beneficial ownership reporting rule pending appeal of the district court decision. On December 23, a panel of judges on the Fifth Circuit stayed that injunction, temporarily reinstating the reporting requirement. However, three days later, on December 26, the Fifth Circuit vacated that stay and reinstated the nationwide injunction. The appeal will now proceed on the merits, with oral arguments scheduled for March 25, 2025. Pending any additional judicial or legislative action, reporting companies are again currently not required to file their beneficial ownership reports. We will continue to monitor any developments that impact these reporting requirements.
