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Filing Requirements Under the Corporate Transparency Act Halted Again

December 27, 2024

We previously notified you that your company may have reporting obligations under the Corporate Transparency Act (“CTA”). The situation has been rapidly changing, and we wanted to make you aware of the current status.

On Dec. 3, 2024, a nationwide preliminary injunction temporarily relieved parties from any filing requirements. On Dec. 23, 2024, the Fifth Circuit Court of Appeals issued a stay of the nationwide preliminary injunction.

However, on Dec. 26, the Fifth Circuit vacated the stay of the injunction, meaning that the injunction has been revived and the filing requirements lifted once again.

How Does This Impact My Entity?

FinCEN continues to accept Beneficial Ownership Information filings on a voluntary basis. We recommend that entities that have not yet filed be prepared to file on short notice if the injunction is again stayed, limited, or overturned.

We Can Help

If you have questions about how to prepare your company for the CTA, please write to us at CTACompliance@maslon.com.

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