We are writing to inform you about a recent legal development regarding the Corporate Transparency Act (CTA) and its requirement for businesses to report beneficial ownership information (BOI) to the Treasury Department.
On Tuesday, December 3, 2024, Judge Amos L. Mazzant III of the U.S. District Court for the Eastern District of Texas issued a nationwide injunction that temporarily blocks the initial BOI filing requirements under the CTA. This decision challenges the CTA’s authority under the Constitution’s Commerce Clause, asserting that the law exceeds Congress’s regulatory powers. As a result, the January 2025 compliance deadline for most businesses is now on hold.
While this ruling suspends reporting requirements for now, it is important to note that FinCen will likely appeal this decision. If a higher court reverses the decision, the compliance deadline could be reinstated, leaving businesses with a short window to meet the requirements.
Nothing is definitive at this time. If you have not already completed your BOI reporting requirements and have questions, please contact the appropriate legal counsel. We will continue to monitor as this situation evolves and update you accordingly.
For additional information, see the December 5, 2024 article appearing in the AICPA’s Journal of Accountancy.
Thank you for your attention to this important matter.
Sincerely,
